DOT Physicals and Medical Cards: What FMCSA-Regulated Employers Need to Know
A driver’s commercial driver’s license may be valid while the driver’s medical certification is expired, downgraded, or otherwise insufficient for the work the employer expects the driver to perform. That distinction can create a serious operational problem: the driver may have a license but still be prohibited from operating a commercial motor vehicle in interstate commerce.
For an employer, the central rule is straightforward: do not allow a driver to operate an FMCSA-regulated commercial motor vehicle unless the driver is currently medically qualified and the company has the required proof in the driver qualification file.
DOT physicals and medical cards are governed primarily by 49 CFR Part 391, not by the FMCSA drug and alcohol testing requirements in 49 CFR Part 382. A DOT physical is also not a drug test. These are separate compliance processes with different purposes, forms, records, and regulatory requirements. Part 382 applies to controlled-substance and alcohol testing for covered CDL drivers, while Part 391 establishes driver physical-qualification requirements.
What Is a DOT Physical?
A DOT physical is a medical examination used to determine whether a driver meets the Federal Motor Carrier Safety Administration’s physical-qualification standards for operating a commercial motor vehicle.
The examination must generally be performed by a medical examiner listed on FMCSA’s National Registry of Certified Medical Examiners. The examiner records the examination on the Medical Examination Report Form, MCSA-5875. If the driver is qualified, the examiner issues or reports the medical certification as required by the driver’s licensing and vehicle circumstances. 49 CFR §391.43(a), (f), and (g).
The examiner—not the employer—makes the federal medical-qualification determination.
An employer may provide the examiner with accurate information about the driver’s job duties, vehicle, work demands, or safety concerns. However, the employer should not pressure the examiner to certify or disqualify the driver.
Who Needs an FMCSA Medical Examination?
The medical-qualification rules are not limited to drivers who hold a commercial driver’s license.
A person subject to Part 391 generally cannot operate a commercial motor vehicle unless medically certified as physically qualified. The applicable physical standards are found in 49 CFR §391.41.
This can include drivers operating in interstate commerce when the vehicle:
- Has a gross vehicle weight rating, gross combination weight rating, gross vehicle weight, or gross combination weight of 10,001 pounds or more;
- Is designed or used to transport more than eight passengers for compensation;
- Is designed or used to transport more than 15 passengers, including the driver, without compensation; or
- Transports hazardous materials in a quantity requiring placards.
Not every driver working for a motor carrier is automatically subject to the federal medical-certification rules. Applicability can depend on the vehicle, interstate-commerce status, job duties, exemptions, and state requirements.
Employers with intrastate-only drivers should also check the rules of the state in which the driver is licensed and operates. States may adopt the federal standards for intrastate drivers, but state-specific exceptions and procedures may apply.
How Long Is an FMCSA Medical Certificate Valid?
A standard FMCSA medical certification may be valid for up to 24 months. The medical examiner may issue a certificate for a shorter period when more frequent monitoring is appropriate.
Under 49 CFR §391.45, a driver generally must be examined and recertified if the driver has not been medically examined and certified during the preceding 24 months. Certain drivers must be examined more frequently. For example, drivers qualified under the insulin-treated diabetes standard or the alternative vision standard generally require annual examinations.
A driver must also be reexamined when the driver’s ability to perform normal duties has been impaired by a physical or mental injury or disease. Employers should therefore avoid treating the expiration date as the only circumstance that can trigger a new examination.
A Two-Year Card Is Not Guaranteed
An examiner may issue a shorter certification period because of a medical condition requiring follow-up. Common certification periods may be three months, six months, one year, or another period selected by the examiner.
The employer should track the actual expiration date shown in the driver’s medical-certification record. It should not assume every driver received a two-year certification.
What Is a DOT Medical Card?
“DOT medical card” is the common name for the Medical Examiner’s Certificate, Form MCSA-5876.
The certificate documents that the medical examiner found the driver physically qualified, subject to any listed restrictions or required variance documents. Examples may include requirements for corrective lenses, a hearing aid, a federal medical exemption, or a Skill Performance Evaluation certificate.
The employer should review the certification information carefully. A certificate may be current but still require the driver to satisfy restrictions or carry supporting variance documentation.
How National Registry II Changed the Process
The Medical Examiner’s Certification Integration rule, commonly called National Registry II or NRII, changed how medical examination results are transmitted for commercial learner’s permit and commercial driver’s license holders.
Beginning June 23, 2025, certified medical examiners electronically submit examination results to FMCSA. FMCSA transmits the information to the applicable State Driver’s Licensing Agency, which posts the information to the driver’s Commercial Driver’s License Information System record.
For CDL and CLP holders, the electronic medical-certification information shown on the CDLIS motor vehicle record is generally the official proof of certification. Motor carriers must obtain the CDLIS motor vehicle record from the current licensing state and place it in the driver qualification file. FMCSA’s NRII materials also explain that carriers no longer separately verify the examiner’s National Registry status for CDL and CLP holders through the previous process.
For drivers who are not required to hold a CDL or CLP, the paper Medical Examiner’s Certificate remains an important certification document. Under 49 CFR §391.43(g)(2)(ii), the examiner must provide the certificate to a medically qualified non-CDL driver and provide a copy to a prospective or current employing carrier upon request.
Temporary Paper-Certificate Exemption Through October 11, 2026
As of July 21, 2026, FMCSA has a temporary exemption related to the NRII transition.
The exemption permits interstate CDL and CLP holders and motor carriers to rely on a paper Medical Examiner’s Certificate as proof of medical certification for up to 60 days after the certificate’s issuance date. It is effective from April 11, 2026, through October 11, 2026. FMCSA has stated that it does not anticipate granting another nationwide NRII waiver or exemption after this period.
This exemption addresses delays in the electronic posting of valid medical information. It does not extend an expired medical certificate or allow a medically unqualified driver to operate.
The employer should:
- Obtain and retain the paper certificate when relying on the exemption.
- Confirm that the certificate was issued no more than 60 days earlier.
- Continue checking the CDLIS motor vehicle record for updated medical-certification information.
- Resolve discrepancies before the 60-day period expires.
- Remember that the electronic record controls if it conflicts with the paper certificate. See 49 CFR §391.41(a)(2)(iv).
What Must the Employer Keep in the Driver Qualification File?
Each motor carrier must maintain a driver qualification file for every driver it employs. The file may be combined with the employee’s personnel file, although employers often restrict access to medical and qualification information.
For medical certification, the required documentation depends on the driver.
CDL or CLP Drivers
The employer generally must obtain a CDLIS motor vehicle record from the driver’s current licensing state showing the driver’s medical-certification status and place that record in the driver qualification file.
When the temporary paper-certificate exemption applies, the employer may use and retain the current paper Medical Examiner’s Certificate for the permitted 60-day period while waiting for the electronic record to update.
Non-CDL Drivers
The employer generally must retain the Medical Examiner’s Certificate or a legible copy. The employer must also document the required verification that the examiner was listed on the National Registry.
Drivers With Medical Variances
When a driver’s qualification depends on a federal medical variance, the employer must also retain the applicable documentation. This might include:
- A Skill Performance Evaluation certificate;
- A federal medical-exemption document;
- A vision-related qualification document; or
- Another FMCSA-issued variance.
The driver may also be required to carry the variance documentation while on duty.
Medical-certification records and CDLIS motor vehicle records may generally be removed from the driver qualification file three years after their date of execution. The driver qualification file itself must be retained throughout employment and for three years after the driver leaves the company. 49 CFR §391.51.
Does the Employer Need the Medical Examination Long Form?
Usually, the employer’s federal recordkeeping obligation concerns proof of medical certification—not the complete Medical Examination Report Form, MCSA-5875, commonly called the “long form.”
FMCSA does not require the medical examiner to provide the completed examination report to the employer. An employer may request it, but the examiner generally should obtain the driver’s authorization before releasing it. Employers that obtain detailed medical information must also consider applicable privacy, disability-discrimination, state-law, and record-separation requirements.
A prudent practice is to collect only the medical information the company has a legitimate need to maintain. The DOT medical certificate or CDLIS record normally provides the qualification information needed for the driver qualification file.
Can a Driver Work With an Expired Medical Card?
Generally, no. A driver who is required to be medically qualified cannot operate an FMCSA-regulated commercial motor vehicle after the medical certification expires.
There is no general grace period merely because:
- The driver has an examination scheduled;
- The clinic was unavailable;
- The driver forgot to renew;
- The employer did not send a reminder;
- The state has not yet updated the license record; or
- The driver previously held a valid certificate.
The NRII paper-certificate exemption does not revive an expired certificate. It applies only when the driver has been medically examined and has a newly issued, valid certificate whose electronic posting may be delayed.
Employers should remove the driver from affected driving duties until valid medical qualification is established. Whether the employer has non-driving work available is an employment and operational decision subject to company policy and applicable law.
What Happens If a Driver Is Found Medically Unqualified?
Since June 23, 2025, when a medical examiner determines that a driver is not physically qualified, the examiner must inform the driver that the result will be reported to FMCSA. Any medical certificates previously issued to that person become invalid and no longer satisfy the federal medical-qualification requirement. 49 CFR §391.43(g)(3).
For an employer, this means a driver should not continue operating based on the expiration date printed on an older certificate after a new examination results in a medically unqualified determination.
Employers should have a process for drivers to report:
- A medically unqualified examination result;
- A pending examination;
- New restrictions;
- A medical variance or exemption;
- A state-license medical downgrade; and
- A physical or mental condition that may require reexamination.
The employer should manage these reports carefully and consistently. The company should focus on whether the driver is qualified for the regulated work, while keeping unnecessary medical details confidential.
What Does “Pending” Mean After a DOT Physical?
A certified medical examiner may place an examination in pending status when additional information or further evaluation is needed.
The additional information or examination must generally be completed within 45 days. Pending status is not the same as a new medical certification. Unless the driver still has another valid certification that has not been invalidated, the employer should not assume that the driver is medically qualified simply because the examiner has not yet issued a final decision. 49 CFR §391.43(g)(4).
Employers should obtain a clear, documented answer about the driver’s current certification status rather than relying on statements such as “the clinic is still working on it.”
A DOT Physical Is Not a DOT Drug Test
A DOT physical evaluates whether the driver meets FMCSA’s medical-qualification standards. A DOT drug test analyzes a regulated specimen for the substances included in the federal testing panel.
Passing a DOT physical does not satisfy the pre-employment drug-testing requirement for a CDL driver covered by 49 CFR Part 382. Likewise, a negative drug test does not establish that a driver is medically qualified under Part 391.
Employers should keep these processes separate:
Process | Primary purpose | Governing rules | Typical documentation |
DOT physical | Determine physical qualification to operate a CMV | 49 CFR Part 391 | MCSA-5875, MCSA-5876, CDLIS MVR and variance documents |
DOT drug and alcohol testing | Detect prohibited controlled-substance use and alcohol misuse | 49 CFR Parts 40 and 382 | Federal CCF, Alcohol Testing Form, MRO and testing records |
Part 40 provides the procedures for DOT drug and alcohol testing, while Part 382 determines which FMCSA drivers are covered and when testing is required.
Common Employer Mistakes
Tracking the Driver’s CDL but Not Medical Status
A license expiration date and medical-certification expiration date are not necessarily the same. Both must be monitored.
Assuming Every Medical Certificate Lasts Two Years
A medical examiner may issue a shorter certification period. Track the actual expiration date.
Relying Indefinitely on a Paper Card
For CDL and CLP holders, the CDLIS record is generally the official proof. The current temporary exemption allows reliance on paper only for the limited 60-day period and only through October 11, 2026.
Failing to Obtain a New CDLIS Motor Vehicle Record
A photocopy of a card does not permanently replace the employer’s obligation to obtain the required CDLIS record.
Ignoring Restrictions or Variances
A valid status may depend on corrective lenses, a hearing aid, a Skill Performance Evaluation certificate, or another variance. Retain and monitor the supporting documentation.
Waiting Until the Expiration Date
Clinic availability, requests for specialist records, pending determinations, and state-processing delays can interrupt operations. Schedule renewals early enough to resolve issues before the current qualification expires.
Treating the Physical as a Drug Test
Combining the two processes can lead to missed pre-employment testing requirements, incorrect forms, or improper recordkeeping.
Employer Checklist for Managing Medical Certifications
A practical employer process should include the following steps:
- Determine which drivers are subject to Part 391.
Review the vehicle, commerce, job duties, CDL status, exemptions, and applicable state rules. - Use a certified medical examiner.
Confirm that the examination is performed by an examiner listed on FMCSA’s National Registry when federal rules require it. - Track actual expiration dates.
Create reminders far enough in advance to accommodate follow-up records or specialist evaluations. - Obtain the proper evidence.
For CDL and CLP holders, obtain the CDLIS motor vehicle record from the current licensing state. For non-CDL drivers, retain the required certificate and National Registry verification. - Review restrictions and variances.
Ensure the driver complies with corrective-lens, hearing-aid, exemption, or Skill Performance Evaluation requirements. - Monitor electronic-record updates.
During the current NRII exemption, use a valid paper certificate for no more than 60 days and follow up on the CDLIS record. - Do not dispatch an unqualified driver.
Remove a driver from affected CMV duties when certification expires or when the company learns that the driver is medically unqualified. - Protect medical information.
Limit access, separate detailed medical records when appropriate, and comply with applicable federal and state privacy and employment laws. - Document the process.
Maintain the CDLIS MVR, medical certificate when applicable, variance documents, verification records, and expiration tracking in or with the driver qualification file.
The Employer’s Practical Takeaway
Medical-card compliance requires more than collecting a photocopy during onboarding.
An FMCSA-regulated employer needs to determine which drivers are subject to the physical-qualification rules, confirm that each driver remains medically qualified, obtain the proper CDLIS or paper documentation, monitor restrictions and expiration dates, and remove drivers from regulated operation when qualification lapses.
The National Registry II process is intended to make medical-certification information more reliable and accessible electronically. During the transition, however, employers must manage both electronic records and temporary paper documentation carefully.
A WorkSAFE Service supports employers with DOT and non-DOT testing services, program administration, C/TPA program management, DOT compliance training, and day-to-day compliance assistance for safety-sensitive workforces. Employers that need help separating their medical-qualification process from their FMCSA drug and alcohol testing program can contact A WorkSAFE Service to discuss their current workflow.
This article addresses FMCSA motor-carrier requirements. Other DOT modes, including the U.S. Coast Guard, use different coverage and qualification rules and should not be treated as interchangeable with FMCSA requirements.
Frequently Asked Questions
Do all CDL drivers need a DOT medical card?
No. Whether a CDL holder must meet the federal medical-certification requirements depends on the type of commerce and the driver’s self-certification category. Drivers operating in non-excepted interstate commerce generally must meet the federal medical standards. Excepted operations and state-regulated intrastate operations may be treated differently.
Can an employer send a driver for a new physical before the current card expires?
Yes. Employers commonly schedule examinations before expiration to avoid operational interruptions. The employer should understand, however, that a new examination can produce a new qualification decision. Since June 23, 2025, a new medically unqualified determination invalidates previously issued medical certificates.
Must a driver carry a paper medical card?
Under the standard rule, CDL and CLP holders generally no longer need to carry the paper certificate after June 23, 2025. Drivers with a medical variance must continue carrying the required variance documentation. Non-CDL drivers subject to Part 391 generally continue to use the paper certificate. During the temporary exemption ending October 11, 2026, CDL and CLP holders may use a newly issued paper certificate as proof for up to 60 days.
Can the employer rely on a picture of the medical card?
A legible electronic image may help document a valid paper certificate when paper proof is permitted. For a CDL or CLP holder, however, it does not permanently replace the required CDLIS motor vehicle record.
Does a medical examiner have to give the employer the driver’s complete examination report?
No. The federal rules do not generally require the examiner to provide the complete MCSA-5875 examination report to the employer. The employer should normally focus on obtaining the certification and qualification documents required for the driver qualification file.
Is an owner-operator subject to the same medical requirements?
Generally, yes, when the owner-operator is subject to Part 391. An owner-operator acts as both the employer and the driver and must satisfy the obligations applicable to each role.
Does the current 60-day exemption give drivers 60 extra days after a medical card expires?
No. The exemption does not extend an expired certificate. It allows reliance on a newly issued paper certificate for up to 60 days while the electronic record is being posted.
Official FMCSA Resources:
