The Federal Motor Carrier Safety Administration has modified its temporary waiver, allowing commercial drivers and motor carriers to use paper medical examiner certificates for up to 60 days after issuance, extending the previous 15-day allowance as state licensing agencies continue transitioning to electronic medical certification systems.
FMCSA announced the waiver modification Aug. 21, extending the grace period for interstate commercial driver’s license holders, commercial learner’s permit holders and motor carriers to rely on paper copies of medical examiner’s certificates as proof of medical certification for up to 60 days after the certificate was issued. The agency initially issued a 15-day waiver on July 14.
The 60-day waiver remains in effect until Oct. 12, 2025, providing additional relief as the trucking industry adapts to the National Registry II electronic transmission requirements that took effect June 23.
The waiver modification addresses ongoing implementation challenges with the Medical Examiner’s Certification Integration rule, which requires certified medical examiners to submit examination results to FMCSA’s National Registry electronically and for state driver licensing agencies to receive and post that information to driver records automatically.
According to FMCSA, only 38 states and the District of Columbia have implemented NRII as of August 21, meaning that twelve states have not yet implemented NRII and are continuing to rely on paper medical certificates. The non-compliant states include Alaska, California, Florida, Iowa, Kentucky, Louisiana, New Hampshire, New Jersey, New York, Oklahoma, Vermont and Wyoming.
The agency determined the extension was necessary to prevent hardship on drivers and carriers experiencing processing delays beyond their control during the transition period. “Since the initial waiver grant on July 14, 2025, FMCSA has become aware that some drivers with a current, valid MEC may face delays beyond 15 days to update their CDLIS driver MVR”, the agency stated.
Key Requirements for Drivers and Fleets
Under the extended waiver, commercial drivers must carry a paper copy of their current, valid Medical Examiner’s Certificate issued by a certified medical examiner within the prior 60 days. The waiver only applies if the driver holds a valid paper certificate issued by a certified medical examiner listed on the National Registry and the motor carrier maintains a copy in the driver’s qualification file.
Motor carriers can maintain copies of drivers’ medical certificates in qualification files for up to 60 days from the certification date before being required to obtain updated motor vehicle records showing electronic medical certification status. After the 60-day period, carriers must verify that electronic exam results have been updated on drivers’ motor vehicle records to avoid compliance issues during DOT audits or inspections.
The waiver does not apply to drivers operating without a current, valid medical certificate or to motor carriers that lack proper documentation within the 60-day window. Drivers who do not have a copy of their current, valid medical certificate that was issued within 60 days prior cannot operate under the waiver provision.
Compliance Recommendations for Industry
FMCSA continues recommending that certified medical examiners issue paper Medical Examiner’s Certificates Form MCSA-5876 to drivers in addition to submitting examination results electronically through the National Registry system, particularly for drivers licensed in non-compliant states.
Motor carriers should verify that certified medical examiners issue drivers’ paper certificates and remain valid within the 60-day window. Fleet managers should monitor motor vehicle record updates after the 60 days and educate staff on the waiver’s conditions and the importance of carrying valid paper certificates, especially in non-NRII-compliant states.
Drivers should request paper certificates from medical examiners, present copies to their motor carriers and continue carrying certificates while operating. They should also work with carriers to ensure exam information is associated with their driving records via state licensing agencies within 60 days after examination and verify accurate information during DOT physicals to prevent transmission errors.
Electronic System Requirements
The National Registry II rule requires medical examiners to upload driver examination results to the National Registry by midnight of the next calendar day following examinations. The results are then electronically transmitted from the National Registry to State Driver Licensing Agencies for posting to driver motor vehicle records.
Once fully implemented, the electronic system will eliminate the need for CDL and CLP holders to carry paper medical certificates, as their medical certification status will be available through state motor vehicle records accessible to law enforcement and inspectors.
For states that have not yet implemented the electronic system, drivers must continue submitting paper medical certificates to state licensing agencies using traditional methods until their state becomes compliant with NRII requirements.
Industry Impact and Timeline
The electronic medical certification system is designed to reduce fraud, improve data accuracy and provide real-time access to driver medical qualification information for roadside inspections and law enforcement. The system eliminates the previous fragmented process where drivers were responsible for physically submitting certificates to state agencies and manual record updates were prone to human error and paperwork bottlenecks.
Transportation Secretary Sean P. Duffy said the digitalized system “will make life easier for lawful truck drivers and harder for bad actors who want to commit fraud” when announcing the rule’s implementation in June. FMCSA Chief Counsel Jesse Elison noted the waiver modification ensures “a level of safety that is equivalent to, or greater than, the level of safety that would be obtained in the absence of the waiver.”
Motor carriers operating in compliant states will no longer need to verify that medical examiners are listed on the National Registry or maintain paper copies of medical certificates in driver qualification files once the transition is complete. Instead, they must verify driver medical certification status through state motor vehicle records, making regular MVR monitoring critical for compliance.
The Medical Examiner’s Certification Integration rule was initially published in 2015 with multiple compliance delays. The rule does not change the medical certification process for non-CDL drivers, who will continue receiving and carrying paper medical certificates.
The waiver provides critical breathing room for the industry as the remaining 12 non-compliant states work to implement necessary information technology systems and procedures. FMCSA has not announced penalties for states that miss compliance deadlines but continues working with state agencies to complete the transition.
Drivers and motor carriers can find additional resources and guidance on NRII requirements through FMCSA’s NRII Learning Center. The agency maintains an updated list of states that have not yet implemented electronic medical certification systems on the learning center website.
