DOT Medical Certification Update: Prepare for the October 11 Deadline

Employers with interstate CDL and CLP drivers should review their medical certification verification process before October 12, 2026.

FMCSA’s temporary exemption allowing drivers and motor carriers to use a paper Medical Examiner’s Certificate as proof of medical certification for up to 60 days after issuance is scheduled to expire on October 11, 2026. FMCSA has stated that it does not anticipate additional nationwide exemptions after this period.

What changes for employers?

Beginning October 12, in states that have implemented National Registry II (NRII), employers should verify an interstate commercial driver’s license (CDL) or commercial learner’s permit (CLP) holder’s medical certification status through the CDLIS motor vehicle record obtained from the driver’s licensing state. The applicable record should be retained in the driver qualification file.

A paper certificate alone will generally no longer serve as the temporary proof permitted under the expiring exemption.

What does CADUCEUS do?

CADUCEUS Selectronically submits the required DOT medical certification data directly to the FMCSA National Registry at the time the examination is completed through our electronic medical record system.

Our team can confirm successful submission and review a specific examination if there is concern about a potential transmission issue. Once submitted, the information is available within the National Registry.

The next step occurs between FMCSA and the driver’s licensing state: FMCSA electronically transmits the certification information, and the state updates the driver’s record. CADUCEUS does not control or have visibility into the timing or status of state level processing. Successful submission to the National Registry does not necessarily mean the state issued MVR has already updated.

What if a recent examination is missing from the driver’s record?

A missing update does not necessarily mean the driver failed the physical. It may reflect a transmission, matching, or state processing issue.

If an examination completed with CADUCEUS is not appearing:

1. Contact CADUCEUS with the employee’s name and date of service. Our team can review the examination’s submission and confirm whether it was successfully transmitted to the National Registry.
2. Have the driver contact their state licensing agency. The agency can address questions about the state record and any additional steps required.
3. Obtain an updated MVR. The employer should verify the required medical-certification status through the licensing state record.

How can employers prepare?

• Schedule renewals early to allow time to resolve discrepancies before the current certification expires.
• Confirm driver information, including name, date of birth, license number, and licensing state.
• Review MVR access and file procedures with the team responsible for driver qualification.
• Brief drivers and dispatchers on the difference between a completed examination, successful electronic submission, and an updated state record.

Will paper certificates disappear?

FMCSA continues to recommend that medical examiners provide paper certificates alongside electronic submission until further notice. However, employers should not assume that receiving a paper certificate confirms the electronic record has been updated. Requirements also differ for non-CDL drivers and drivers licensed in states that have not implemented NRII.

CADUCEUS is here to support your DOT examination needs and help review submission questions. For assistance with a recent examination, contact our team with the employee’s name and date of service.