Optimizing Driver Hiring and Compliance: What to Know for FMCSA Physical Updates

Authors: Andrew Williams, Director of Client Solutions, Transportation and Heather Horn, VP of Product Fulfillment, D&HS

In our last blog, Optimizing Driver Hiring and Compliance: Ways to Automate Compliance Processes, we discussed the challenges of hiring and maintaining compliance for drivers and regulated populations while improving efficiency and effectiveness.

Continuing on with our Optimizing Driver Hiring and Compliance series, we’ll be diving into two key events that may greatly impact the way transportation companies currently handle Department of Transportation (DOT) physicals. We’ll then share ways your company can prepare for these changes to limit potential interruptions to your business operations and keep your drivers on the road.

15,000 Medical Examiner’s Certificates Voided

This past April 11, two Houston-area medical examiners were under investigation due to concerns over the high volume of physical exams performed. The Federal Motor Carrier Safety Association (FMCSA) determined that the exams issued between March 2023 and March 2025 were not in compliance with guidelines and standards for determining if a driver was physically qualified to operate a commercial vehicle. As a result, the FMCSA voided over 15,000 Medical Examiner’s Certificates (MECs). If these drivers fail to obtain a new certificate by May 10, the driver’s respective state drivers licensing agency (SDLA) will downgrade the driver’s commercial driver’s license (CDL).

How Does This Impact Your Drivers?

If you haven’t had drivers decertified, this may seem like it doesn’t affect your business, and that might be true. However, this incident is part of an ongoing trend where the FMCSA is increasing efforts to ensure compliance with processes, and it’s likely that more incidents like this will occur in the future, putting your drivers at risk for decertification if you’re not prepared.

To limit the risk of this scenario happening with your drivers, it’s important to work with a trusted partner to build a program that facilitates your exams to address compliance requirements, whether you hire locally, regionally, or nationally.

Additionally, we recommend that your drivers take a physical through your program even if they have a current Medical Examiner’s Certificate (MEC). Accepting an independently issued MEC gives you little to no control over the process, which opens your organization up to the risk of decertification.

Medical Examiner’s Certificates (MEC) Upcoming Updates

In response to the Houston-area medical examiners investigation, beginning on June 23, 2025, the FMCSA is changing the protocols[1] for tracking and accounting for MECs for CDL holders. There will be no changes for non-CDL commercial vehicle drivers. At present, drivers receive a paper copy of the MED by the examiner, which the driver then submits to their state’s DMV to update their CDL information. Additionally, the driver provides their employer with a copy of the card for inclusion in their driver qualification file (DQF). While the current process is straightforward, it’s manual and time-consuming.

The new process aims to eliminate these manual steps. Once a provider issues an MEC, they are responsible for electronically submitting this information to the FMCSA, which will then automatically pass to the state to update the driver’s license. Employers will want to pull a motor vehicle record (MVR) to confirm that the status has been updated.

How Does This Impact Your Drivers?

Again, it’s important to note that this change does not impact CDL self-certification requirements. Drivers must still self-certify, which can vary by state, but usually occurs during licensing actions, such as renewals. Although this change will improve the overall process that has historically been manual, there may be gaps in the process while the support structure ramps up, potentially impacting your ability to put drivers on the road.

Since paper medical card usage will expire, if the provider, FMCSA, or state licensing body does not complete their process, it is possible your driver may be downgraded automatically once the time period has elapsed, pulling them off the road even though they have completed the requirement and are just waiting for record-keeping to update. Additionally, if a driver does not pass the test, their downgrade will happen immediately, and they can no longer run out the remainder of the time on their previous card.

4 Things You Can Do To Help Minimize Disruptions

Due to the MEC change, the process is managed entirely by the providers, FMCSA, and the state. Even with these changes, there are four things you can do to put yourself in the best position to minimize disruptions:

  • Follow the guidance on MECs done outside of your program. Exercising control over your network and ensuring you use trusted providers can drastically reduce potential issues with the process.
  • To give yourself runway for hiccups as the program ramps up, consider the expiration date of the MEC as two weeks prior to when it actually expires. This will help to provide a safety net for you during the transition time.
  • Start running a daily MVR check once the physical is complete until you see the update take place. We recommend starting this three business days post physical completion, which is why we suggest completing the physical two weeks in advance.
  • Have your drivers request and maintain a copy of their MEC until it shows on their license. While the paper MEC cannot replace it, it helps to troubleshoot issues with the clinic, FMCSA, or SDLA if one arises.

Adapting to New Processes

Staying ahead of FMCSA physical updates is crucial for transportation companies to minimize disruptions. As the FMCSA transitions to electronic submission of MECs, companies must adapt to new protocols and proactively manage their drivers’ compliance. By following the recommended steps, such as early physical completion and daily MVR checks, businesses can safeguard their operations and keep their drivers on the road. Embracing these changes will not only enhance efficiency but also contribute to the overall reliability of the transportation industry.

To read more about this upcoming change, click here.

To learn more about our transportation solutions, click here.

[1] FMCSA National Registry

This content is offered for informational purposes only. First Advantage is not a law firm, and this content does not, and is not intended to, constitute legal advice.  Information in this may not constitute the most up-to-date legal or other information.

Readers of this content should contact their own legal advisors concerning for their particular circumstance.  No reader, or user of this content, should act or refrain from acting on the basis of information in this content.  Only your individual attorney or legal advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.  Use of, and access to, this content does not create an attorney-client relationship between the reader, or user of this presentation and First Advantage.

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