The regulations for commercial vehicle drivers are changing in regards to Federal Medical Certificates (medical cards). The changes affect various kinds of drivers differently. The rules remain the same as to which drivers need a medical card while operating a CMV, but drivers will now have to provide an up-to-date copy of this card to the DMV when they obtain it. As part of this process, all CDL holders will now also have to self-certify their classification in which they operate (which will determine their requirements for filing their medical card with the state) by 2014, and some may have to do so earlier than that.

There are also some changes in regards to who tracks drivers with medical cards. Currently, all trucking outfits are responsible for tracking the expiration of medical cards for their drivers. By January 2014, the states will be required to begin tracking the drivers who are maintaining a valid medical card. If the state’s DMV doesn’t have a card on file for a driver, they’ll suspend their license. Most states are starting this process now to ensure compliance by 2014, beginning with those who are receiving Federal Medical Certificates and CDLs for the first time or renewing them.

Drivers in all states, who are required to file a Federal Medical Certificate, will have to comply with these new requirements by January 30, 2014. In most states, you are now required to show your medical card when renewing a CDL license for interstate commerce. If you renew your CDL but don’t show your medical card, you may be restricted to intrastate-only travel as a result. A number of our clients have reported that their drivers have visited the DMV, renewed their license without showing their medical card (since they haven’t had to in the past), and then later realized that the license they got was restricted to intrastate commerce. Make sure your drivers are aware of this requirement when they renew their CDL. From now on, any time a driver gets a new medical card (good for two years), they will need to notify the DMV when it expires.

Another new requirement is that all CDL holders will have to self-certify their type of vehicle operation, which will determine if they need to submit a Federal Medical Certificate to the DMV or not. The new regulations do not change who is required to maintain a medical card, but they do require drivers to report their exemption, if they have one. CDL holders who do not file a medical card with the DMV or report an exemption will be assumed to be non-compliant, and their licenses will be suspended on January 30, 2014. With that said, let’s look at who needs a Federal Medical Certificate.

To determine whether a driver needs to file a Federal Medical Certificate with the state, you need to know two things: are they an interstate or intrastate driver, and are they in an excepted industry? If a driver crosses a state line at any point during a normal trip, they are an interstate driver. If a driver conducts all of their business within one state, they are an intrastate driver. Exceptions are a little more difficult to determine, but some of the DOT’s exceptions include school bus operations, operation of fire trucks or other rescue vehicles, farming operations (transportation of machinery and/or crops), operation of a private carrier of passengers, and transportation of personal property not for compensation or commercial enterprise. These are just a few of the many DOT exceptions, and each state has a list of their own, as well. Be sure to check if there are special exceptions in your state.

There are four options (Tiers) to choose from when determining your classification. Tier 1: Non-Excepted Interstate. You need to provide a valid medical card to the DMV and maintain that the card is up-to-date and on record when you renew or get a new one. Tier 2: Excepted Interstate. No medical card is needed. Tier 3: Non-Excepted Intrastate. You need a valid medical card and you must provide it to the DMV only when a license is issued. Tier 4: Excepted Intrastate. No medical card is needed. Make sure that you are compliant with the requirements for your tier, making note of any additional state or employer exceptions.