The CDL Medical Card Is Three Employer Duties, Not One Piece of Paper

49 CFR 391.43(a) is one sentence long: except as provided in paragraph (b), the medical examination “must be performed by a medical examiner listed on the National Registry of Certified Medical Examiners under subpart D of part 390.” The driver picks the clinic. You are the one who has to prove the examiner was listed on the day the certificate was issued — 391.23(m)(1) makes that verification a condition of letting the driver operate at all.

Three separate duties sit behind the phrase “medical card,” and for CDL holders the paperwork behind the third one changed on June 23, 2025.

Who is allowed to issue a CDL medical card?

Only a medical examiner listed on the National Registry, with two narrow exceptions in 391.43(b). 390.5 defines a medical examiner as “an individual certified by FMCSA and listed on the National Registry of Certified Medical Examiners in accordance with subpart D of this part” — the listing is the qualification, and a physician who let it lapse is not one. Neither exception creates a second route to a certificate: an ophthalmologist or optometrist may perform only the vision portion specified in 391.41(b)(10), and a certified VA medical examiner “must only perform medical examinations of veteran operators.”

What you do: look the examiner up by name and registry number on FMCSA’s National Registry before you file the certificate, and record the result. The name, office address and telephone number are on the report because 391.43(g)(1) requires them there.

The gotcha: you verify status as of the issuance date, not today. That lookup survives a removal: 390.115(g) says a removed person’s information “remains publicly available for 3 years, with an indication that the person is no longer listed on the National Registry of Certified Medical Examiners as of the date of removal.” A later removal does not spoil a certificate that was valid when issued — but a certificate from someone already off the list was never good, and that is your finding.

How long is a CDL medical card valid?

24 months at the outside, and the regulation itself names five other situations where the interval is shorter or the exam is triggered outright. 391.45 is written as a list of persons who must be examined, which is why the “two-year card” is better read as a maximum interval between exams.

Below those ceilings the examiner may set a shorter date, and the certificate governs. FMCSA’s recommendations and guidance for examiners, published as appendix A to part 391, say in the criteria for 391.41(b)(7) that “in cases where more frequent monitoring is required, a Medical Examiner’s Certificate, Form MCSA-5876, for less than the maximum certification period may be issued.” The blood pressure criteria for 391.41(b)(6) are more specific: a driver in the Stage 1 range “may be medically certified to drive for a 1-year period,” and one in the Stage 2 range “may be given a one-time certification of 3 months to initiate or adjust antihypertensive drug therapy.”

A three-month card is a normal document, not a red flag — but a fleet that schedules every physical two years out runs that driver expired inside a quarter. 391.45(g) is the one no calendar catches: an injury or illness that impairs the driver’s ability to perform normal duties requires re-examination whenever it happens, and you are the party who knows it happened.

What goes in the driver qualification file?

For a non-CDL driver, the certificate and a verification note. For a CDL holder, the CDLIS motor vehicle record. This is the split that gets audited, and it is set out in 391.51(b).

Two details carry most of the risk.

First, the CDLIS MVR is a specific record — defined at 384.105 as “a report generated from the CDLIS driver record” — and 391.51(b)(6)(ii) requires it be “obtained from the current licensing State and placed in the driver qualification file.” The state MVR you already pull for the annual review is not automatically that record. The same paragraph says what you will see if the driver never gave the state a certificate: after January 30, 2015, “a non-excepted, interstate CDL holder without medical certification status information on the CDLIS motor vehicle record is designated ‘not-certified’ to operate a CMV in interstate commerce.”

Second, 391.23(m)(2)(i) makes you verify and document “the type of operation the driver self-certified that he or she will perform” under 383.71(b)(1) — non-excepted interstate, excepted interstate, non-excepted intrastate, or excepted intrastate. A driver self-certified as intrastate, dispatched across a state line, is a qualification problem no medical card fixes. Check it against the work you intend to give him, at hire, alongside the rest of the DOT hiring sequence.

What changed on June 23, 2025?

FMCSA now sends the certificate information to the State, and the paper card stops being the CDL holder’s proof. Examiners have reported results to FMCSA since June 22, 2018 under 391.43(g)(5)(i)(B); what turned on in 2025 is the leg from FMCSA to the licensing State. Under 383.71(h)(3)(ii), a non-excepted interstate CDL or CLP holder keeps a “certified” status because “FMCSA will provide the State with an electronic copy of the medical examiner’s certificate information,” not because the driver walks a card into the DMV. The Medical Examiner’s Certification Integration final rule was published April 23, 2015 (80 FR 22790); FMCSA extended the compliance date for several of its provisions from June 22, 2021 to June 23, 2025 (86 FR 32643).

Three things follow on the employer side:

• The examiner no longer hands a paper certificate to a CDL or CLP holder. 391.43(g)(2)(ii) directs the examiner to complete and furnish the certificate only where the person “will not be operating a commercial motor vehicle that requires a commercial driver’s license or a commercial learner’s permit.”
• The 15-day paper window closed. 391.51(b)(6)(ii) and 391.23(m)(2)(iii) allowed a copy of the certificate submitted to the State to serve as proof for up to 15 days from issuance — “through June 22, 2025.”
• A not-qualified finding kills the old card. Under 391.43(g)(3), when an examiner finds a driver not physically qualified on or after June 23, 2025, “all medical examiner’s certificates previously issued to the person are not valid and no longer satisfy the requirements of § 391.41(a).”

A standing rule now does more work: 391.23(m)(4), 391.41(a)(2)(iv) and 383.71(h)(4) each provide that where the medical certification information FMCSA provides electronically conflicts with a paper copy, the electronic information controls. And 391.41(a)(2)(iii) still requires a CDL or CLP holder who qualified through a medical variance to carry that variance documentation when on duty.

Where does a medical card failure show up in an audit?

Three critical entries, one acute entry, and one automatic new entrant failure. Appendix B to part 385 lists § 391.45(a) “Using a driver not medically examined and certified,” § 391.45(b) “Using a driver not medically examined and certified during the preceding 24 months,” and § 391.51(b)(6) “Failing to maintain medical examiner’s certificate in driver’s qualification file” as critical regulations. § 391.11(b)(4), “Using a physically unqualified driver,” is acute.

For a new entrant the exposure is sharper. § 391.11(b)(4), there worded “Knowingly using a physically unqualified driver,” is item 12 of the sixteen violations in 385.321(b), and the table’s guideline for it is “Single occurrence” — one such driver fails the safety audit outright, with no pattern analysis and no percentage threshold.

The distinction matters: a missing document is a filing failure, an expired or absent certification is a use-of-driver failure, and the second is the expensive one.

What the medical certificate cannot tell you

It certifies a body against 391.41(b) on one day. It says nothing about whether he shows up, how the equipment comes back, or whether he finished the last contract. The DQ file has no field for any of that, and the hiring investigation under 391.23(d) and (e) asks previous employers about accidents and drug and alcohol history — not whether the driver was reliable, which is most of what makes a bad hire expensive.

That is the layer cdlscan is built for: reviews written by carriers who actually employed the driver. A name search fits in the same sitting as pulling the CDLIS MVR, and our overview of how carrier-written driver reviews work covers the format.

The boundary matters in an audit, so say it plainly: this sits on top of the required medical certification checks, never in place of any part of them. The examination under 391.43, the registry verification under 391.23(m), the CDLIS MVR under 391.51(b)(6)(ii) and the re-examination triggers in 391.45 are legally required, and nothing here discharges any of them. If you intend to rely on third-party information about a driver as a factor in an employment decision, ask the provider which category of information they consider it under the Fair Credit Reporting Act, and confirm which obligations attach with your own counsel first.

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