FMCSA's temporary waiver allowing drivers and carriers to rely on a paper copy of the medical examiner's certificate as proof of medical certification expires on Oct. 11, 2026.
The waiver ran for six months, from April 11, 2026, and was itself an extension of earlier relief. Reporting on the latest extension indicates FMCSA does not expect to issue another nationwide one.
This is a news summary, not legal advice. Check FMCSA's National Registry site for any last-minute change before Oct. 11.
Why the waiver existed
Under the Medical Examiner's Certification Integration rule, usually called NRII, the examiner no longer hands the driver a card to take to the state. The examiner submits the result electronically to FMCSA's National Registry, FMCSA passes it to the state driver licensing agency, and the state posts it to the driving record.
That chain has three handoffs, and any of them can run late. The waiver covered the gap: while the result was working its way through, the paper MCSA-5876 certificate counted as proof for up to 60 days from the date it was issued. It was granted in response to a request from the Commercial Vehicle Safety Alliance, so that compliant drivers weren't penalised for delays they couldn't control.
We covered how that chain fails, and how it quietly downgrades CDLs, in our explainer on electronic medical certificate filing.
Where the states stand
As of the waiver notice, 45 states and the District of Columbia had implemented NRII. Five had not and were still relying on the paper certificate:
- Alaska
- California
- Kentucky
- Louisiana
- New Hampshire
If you run drivers licensed in any of those five, watch FMCSA's guidance closely over the next two weeks. What happens to their certification process after Oct. 11 depends on how far each state has got.
What changes on Oct. 11
For drivers licensed in states that have implemented NRII, the practical change is simple. The paper certificate stops being the safety net. The state driving record is what counts, at roadside and in your driver qualification file.
That means a driver who passes a physical on Oct. 5 and whose result has not posted by the time they are inspected could be treated as uncertified. The exam happened, the driver did everything right, and the record still says otherwise.
What to do before Oct. 11
- Pull a current record for every driver who had a DOT physical in the last 60 days. Confirm the new certification has posted. If it hasn't, find out where it is stuck now, while the paper copy still covers them.
- Schedule upcoming physicals early. A driver whose card expires in late October should not be booked for the day before it expires. Leave room for the result to post.
- Check the examiner is on the National Registry before the appointment, not after. An exam by an examiner who isn't currently certified doesn't count.
- Keep the paper copy anyway. It won't be proof after Oct. 11, but it is evidence of when the exam happened and who performed it. That helps you fix a posting error, and it belongs in your driver qualification file.
- Know who to call. When a certification doesn't post, the fix usually starts with the examiner who submitted it. Make sure your drivers know to go back to them first.
Quick answers
When does the paper medical card waiver end? Oct. 11, 2026.
What did it allow? Drivers and carriers could use a paper copy of the medical examiner's certificate as proof of medical certification for up to 60 days after it was issued.
Which states haven't implemented NRII? As of the waiver notice: Alaska, California, Kentucky, Louisiana and New Hampshire.
What proves certification after Oct. 11? In NRII states, the driver's state record, which the examiner's electronic submission updates.
