FMCSA National Registry II Waiver: What Motor Carriers Need To Know

Earlier this year, the Federal Motor Carrier Safety Administration (FMCSA) was set to instate the last stages of the Medical Examiner’s Certification Integration final rule, known as National Registry II or NRII. But these requirements have not fully gone into effect just yet, due to a waiver FMCSA issued in July, giving states, motor carriers, medical examiners and drivers a few more months to do things the old way, using physical medical examiner’s certificates (MECs) — aka Med Cards.

Here’s what motor carriers need to know about the NRII waiver. 

What’s the background?

The NRII rule, which was published in 2015, modernizes how driver medical certification is shared, replacing the outdated paper-based process with an all digital system. Some aspects of NRII were implemented in 2015, and others went into effect in 2018. There have been several delays along the way. 

Medical examiners will now electronically transmit drivers’ medical examination results to the FMCSA, so drivers will no longer have to submit their Med Cards directly to the state themselves.

The deadline for the final requirement was June 23, 2025. This step requires FMCSA to electronically transmit driver medical examination results from its National Registry to State Driver’s Licensing Agencies (SDLAs), which will then post the information on the Commercial Driver’s License Information System (CDLIS) driver motor vehicle record (MVR). 

What is the NRII waiver & why is it needed?

Despite the June 23 deadline, 12 states have not yet implemented NRII. They are: 

Because these states are not yet ready to comply, FMCSA issued the waiver, which is in effect until Oct. 12, 2025. 

The NRII waiver allows CDL holders, CLP holders and motor carriers to continue relying on paper copies of MECs as proof of drivers’ medical certification for up to 15 days after the date the certificate is issued. 

What should motor carriers do now?

Motor carriers in the 12 states that have not implemented NRII should handle things the “old way,” meaning: 

• Instruct drivers to submit a paper copy of their MEC to their SDLA within 15 days; 
• Continue verifying medical examiner information on the National Registry; and
• Run an MVR within 15 days of medical certification, ensuring it reflects the new medical certification, and add it to the driver’s qualification file. 

If you’re in a state that has implemented NRII, we recommend that you get in the habit of doing things the “new way,” even though you technically fall under the waiver as well. This means: 

• Run an MVR two to three days after the new medical certification was issued, as medical examiners have until midnight the day following the exam to submit the information to FMCSA. You no longer have a 15-day grace period to run an MVR showing medical certification; this is now the only acceptable form of proof of certification.
• In the event that the new medical certification is not shown on the MVR, contact the clinic directly and ask them to re-submit the information.

No matter what state you’re in, FMCSA has some helpful outreach materials, including fact sheets, brochures and FAQs for drivers, motor carriers, states, medical examiners and law enforcement, on its NRII Learning Center web page. 

It’s also important to know that MVR monitoring services do not notify motor carriers when Med Card-related activity occurs on a driver’s motor vehicle record. For example, if a driver’s license is downgraded due to his or her MEC not being on file, you would not receive an alert, even if you were enrolled in MVR monitoring. The monitoring services do not receive these updates from the state. You must run an MVR to get news about downgraded licenses. 

Keep in mind that MVRs, which will soon become the sole source of medical certification information, are not free. That’s why we recommend running MVRs two to three days following the exam to remain compliant and avoid wasting money. Clinics have until midnight on the day following the medical exam to submit MECs electronically to the FMCSA.

How does Avatar help?

Avatar can help you comply with the NRII and associated changes in a few ways. 

First, companies that are using a physical Med Card for the time being are still required to verify the medical examiner is listed in the National Registry. The Avatar Assistant’s Med Card Scanner allows you to automatically extract data from medical cards and cross-reference medical examiner details with the registration database, saving time and preventing data-entry errors. 

Avatar also integrates with MVR and driver monitoring software powered by SambaSafety, so you can seamlessly order MVRs for any reason (pre-hire, annual, monitoring events or medical examinations) and automatically add them to DQ files. 

Finally, all Avatar customers have access to dedicated Client Success Managers, who are an extra set of eyes and ears on compliance issues just like this one. 

Avatar offers Compliance Services to help you manage your DQ files. Let our team of compliance specialists manage the process of ordering and reviewing MVRs, in addition to all other DQF documents. We are a partner, not just a platform.

If that level of support and guidance isn’t something you’re getting with your current recruiting, safety and DOT compliance software platform, contact Avatar today to book a demo.