đźš› FMCSA Medical Certification Changes
Q: What is the FMCSA National Registry Integration Initiative (NRII) Rule?
A: The National Registry Integration Initiative (NRII) mandates that certified medical examiners submit DOT medical exam results directly to the National Registry. The FMCSA will then electronically transmit those results to state licensing agencies, eliminating the need for commercially licensed drivers to submit paper certificates.
Q: When does the new rule take effect?
A: The rule as well as the changes to our platform, go into effect on June 23, 2025.
Q: Will all states have implemented NRII by June 23, 2025?
A: No. The list of states which have not yet implemented NRII is maintained by the FMCSA here. Drivers licensed in states that have not implemented NRII must continue to submit a paper copy of their Medical Examiner’s Certificate, to their state licensing agency.
Our platform accommodates both scenarios. For drivers licensed in states that have not yet implemented NRII, your users of our platform should continue to upload Medical Certificates via platform alerts. Should they choose the self-service option and opt to have the driver provide their Medical Certificate details, both scenarios are covered.
Q: Do drivers still need to carry paper medical cards before the deadline?
A: Yes. Until June 23, 2025, commercially licensed drivers must continue to carry and submit physical copies of their medical certificates to their state licensing agencies.
Q: What happens after the deadline?
A: After June 23, 2025:
- Medical examiners will submit results electronically.
- Commercially licensed drivers will no longer need to submit paper certificates.
- Employers won’t need to manually verify medical examiner credentials.
Q: What should employers do in the meantime?
A: Employers must continue verifying that their drivers are certified by a listed medical examiner and maintain proper documentation in driver qualification files.
Q: Does this impact non-CDL drivers that are FMCSA regulated?
A: No. The electronic submission of medical certificate information to the SDLAs to display medical certificate information on motor vehicle reports is only for commercial license holders.
For those drivers who are personally licensed but operate in an FMCSA-regulated role, they will still be issued a paper medical certificate and employers will be responsible for the verification of that medical certificate against the FMCSA National Registry.
đź“Ś Product & Feature Changes
Alerts:
Q: How will the Medical Certificate - No Certificate on File, Expiring, & Expired platform alerts change?
A: These alerts will generate based on the same conditions as before, however, after June 23rd, there will be a new option available to customers for resolving the alert when their commercially licensed driver has already completed a physical - Order MVR. Since commercially licensed drivers will no longer be given a copy of their medical certificate after completing their physical, it will be no longer appropriate to ask your organization's users of our platform to upload a copy.
Instead, within the alert itself users will be able to provide the Issue Date for their driver’s latest medical certificate and click Order MVR, and we’ll electronically retrieve their Medical Certificate from the state licensing and update their Compliance File automatically:
Q: How will the Medical Certificate - No Certificate on File, Expiring, & Expired platform Self-Service alerts change?
A: Like the platform alert, the associated self-service option—which drivers will see if your organization chooses to have them provide their Medical Certificate details—allows for electronic retrieval of a commercially licensed driver’s Medical Certificate by ordering an MVR. If the driver enters an issue date of June 23, 2025, or later, they won’t need to upload a document.
Q: How will the alert differ between commercially and non-commercially licensed drivers?
A: The Order MVR option will not be available on alerts for drivers with a non-commercial licenses, as they're excluded from the new rule requiring that medical certificates be transmitted electronically by physicians.
However, during the transition period and over the next ~2 years, there will still be commercially licensed drivers who hold physical copies of their Medical Certificate, and therefore, the alert will still display the upload option until the transition period is over:
Platform:
Q: Once a physical is completed by a driver, when will a Medical Certificate MVR be ordered?
A: For drivers who are commercially licensed, in a state that's NRII compliant, & enrolled in DQFM, the Medical Certificate MVR will be ordered 2 calendar days after the date on which the physical was completed. Given that commercially licensed drivers’ medical certificates will be transmitted directly to the FMCSA registry, it’s no longer necessary to wait 15 days before ordering a Medical Certificate MVR.
Q: Will electronically retrieved Medical Certificates enter Foley's Document Review Service?
A: No.
Q: Will every commercially licensed driver who completes a physical after June 23rd, 2025, not be given a physical copy of their medical certificate?
A: While we expect physicians to follow the new rule, some may still issue physical documents to commercially licensed drivers. If your commercially licensed driver completes their physical after June 23rd and receives a physical certificate—regardless of whether it was ordered through Foley—we recommend not uploading that document to our platform, unless your driver is licensed in a state that's not yet compliant with NRII.
đź’ł Pricing & Billing
Q: Will this change have billing impact?
A: A billable event occurs in these scenarios:
- Your platform user chooses the Order MVR option via the Medical Certificate - No Certificate on File, Expiring, or Expired platform alerts, to electronically retrieve your commercially licensed driver's Medical Certificate (an MVR is ordered).
- Your platform user opts to send your driver a Self-Service link via the Medical Certificate - No Certificate on File, Expiring, or Expired platform alert and the driver indicates in the self-service module that their Medical Certificate was issued after 6/23/2025 (an MVR is ordered).
- A DOT physical is completed by one of your drivers (an MVR is ordered once the Medical Certificate details have been transferred to the respective state licensing agency).
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