If your CDL medical card expires, you may not drive a commercial motor vehicle in interstate commerce from that day: federal rules give no grace period. The state then marks your record "not certified" within 10 days and must complete a downgrade of your CDL within 60 days unless a new certificate arrives or you change your self-certification. This page explains the four self-certification categories that decide whether you need a medical card at all, how the certificate gets to the state since June 2025, and what to do at each stage of a lapse.
What the "medical card" is
The card is the medical examiner’s certificate (Form MCSA-5876) issued after a DOT physical by an examiner on FMCSA’s National Registry (391.43(a), (h)). It shows you meet the physical standards in 391.41(b). How long it lasts is set by 391.45: 24 months by default and 12 months or less in several cases, covered on the how often you need a DOT physical page. This page is about the paperwork around it for CDL and permit holders.
Step one: your self-certification
Every CDL and permit holder must tell the state which kind of driving they do (383.71(b)(1), (g)). The choice decides whether the state needs your medical certificate.
| Category | What you certify | Medical certificate to the state? |
|---|---|---|
| Non-excepted interstate (often coded NI) | You operate or expect to operate in interstate commerce, are subject to and meet Part 391, and must have a medical certificate under 391.45 | Yes |
| Excepted interstate (EI) | You operate in interstate commerce but only in operations excepted from all or part of Part 391 by 390.3(f), 391.2, 391.68 or 398.3 | No federal requirement |
| Non-excepted intrastate (NA) | You operate only in intrastate commerce and are subject to your state’s driver qualification rules | Not under 383.71(h); your state’s rules decide |
| Excepted intrastate (EA) | You operate intrastate, only in operations excepted from all or part of the state’s qualification rules | Per state rules |
The letter codes are the common state shorthand; the rule uses the words. Most drivers who work for a trucking company, or haul anything that crosses a state line, are non-excepted interstate. "Interstate commerce" in 390.5T includes a trip between two places in one state when the freight is part of a movement that started or will end outside the state, so a local driver moving imported containers from a port can be interstate without leaving the state.
Who is excepted
The excepted interstate category is narrow. It covers, for example:
- transportation by the federal government, a state or a political subdivision (390.3T(f)(2));
- fire trucks and rescue vehicles in emergency and related operations (390.3T(f)(5)), and transporting human corpses or sick and injured persons (390.3T(f)(4));
- custom harvesting, beekeepers moving bees, and some farm vehicle drivers (391.2(a) to (c)); drivers of covered farm vehicles are outside the physical qualification rules (391.2(d));
- private carriers of passengers that are not a business, for which the medical exam and certificate rules do not apply (391.68(c)).
If you are not sure you fit one of these, you are probably non-excepted.
How the certificate reaches the state now
Before 23 June 2025, drivers handed or mailed a paper copy to the state licensing agency. The rules changed on that date:
- The examiner must transmit your results to FMCSA electronically by midnight (local time) of the next calendar day after the exam (391.43(g)(5)(i)(B)).
- For a CDL or permit holder, FMCSA passes the certificate information to the state, and the state posts it to your record (383.71(h)(3)(ii); 383.73(o)(1)(ii)). Medical variances received from FMCSA are posted within 1 business day (383.73(o)(1)(ii)(C)).
- The examiner issues a paper certificate to the driver only when the driver will not be operating a vehicle that requires a CDL or permit (391.43(g)(2)(ii)).
- A CDL or permit holder with a current certificate no longer has to carry it (391.41(a)(2)(i)(B)).
- If FMCSA’s electronic record and a paper copy disagree, the electronic record controls (383.71(h)(4); 391.41(a)(2)(iv)).
State systems switched over on their own timetables. California’s DMV, for example, says that from 27 July 2026 interstate (NI) commercial drivers may no longer submit their own medical exam records in person, by mail or online: the examiner submits them through the National Registry. Intrastate drivers there can still submit paper forms. So "how do I upload my DOT physical" now has a short answer for most interstate CDL drivers: you don’t; the examiner does. Check your state’s page for its current process.
When the certificate expires: the timeline
Three rules run at once, and only one of them is about you driving.
- You must stop driving. 391.41(a)(1)(i) says a person subject to Part 391 must not operate a CMV unless medically certified. There is no grace period in the text. Your employer must also not let you drive; the carrier keeps the proof in your qualification file (391.51(b)(6)) and verifies your self-certification and medical status on the state record before letting you drive (391.23(m)(2)).
- Within 10 calendar days of the certificate expiring, the state updates your medical status to "not certified" (383.73(o)(2)(ii)). The same happens when a variance expires or is rescinded, or FMCSA voids a certificate.
- The state notifies you and starts the downgrade. Under 383.73(o)(4)(i) it tells you the CDL privileges will be removed unless you are examined and certified again or change your self-certification to excepted or intrastate driving, if the state allows that. The downgrade must be completed and recorded within 60 days of your status becoming "not certified".
A downgrade, as defined in 383.5, means either the state lets you change your self-certification to excepted interstate or intrastate driving, or it removes the CDL privilege from your license. Losing the privilege means you are back to a regular license for CMV purposes, and getting the CDL back is a state procedure that can involve more than a new physical. Ask your state what it requires, and do not wait for the 60 days to run out.
Example: a lapse and a recovery
Example, applying the sections above. A non-excepted interstate driver’s certificate expires on 31 March. On 1 April she may not drive a CMV in interstate commerce, and her carrier may not dispatch her. By 10 April the state has marked her "not certified" and sends a notice. She books a physical for 14 April and passes. The examiner transmits the result by midnight on 15 April; FMCSA sends it to the state, which posts it to her record. Once her record shows "certified" again she can be dispatched. Had she waited past the 60-day mark from her not-certified date, the state would by then have been required to complete the downgrade.
A failed or delayed exam
- Not qualified. Since 23 June 2025, when an examiner finds you not physically qualified, the examiner tells you it will be reported to FMCSA, and all certificates previously issued to you stop being valid (391.43(g)(3)). Your old card does not run to its printed date. The state is then required to update your status and start the downgrade steps above (383.73(o)(2)(ii), (o)(4)(i)).
- Determination pending. An examiner may delay a decision for up to 45 days to get more information or tests, and the pending status is reported to FMCSA (391.43(g)(4)). Book the renewal early enough that a delay does not run past your expiry date.
The examiner decides whether you meet the standards; nothing on this page is medical advice. The standards themselves are on the DOT physical requirements page.
Waivers, exemptions and SPE certificates
Some drivers who do not meet a standard in 391.41(b) can still be certified through a medical variance from FMCSA: an exemption letter or a Skill Performance Evaluation (SPE) certificate (391.41(a)(3)(ii)). The SPE certificate is for loss or impairment of limbs (391.49). Two further routes are written into the standards themselves: the alternative vision standard in 391.44 and the insulin-treated diabetes standard in 391.46, both on a 12-month cycle.
Two paperwork points apply to variances:
- A CDL or permit holder certified by virtue of a variance must keep the variance document, original or copy, with them whenever on duty (391.41(a)(2)(iii)). This is the one medical paper interstate CDL drivers still carry.
- The state notes a variance on the license with the V restriction (383.95(g)), and the variance has its own expiry date on your record (383.73(o)(1)(ii)(C)). When it expires, the same downgrade steps apply.
Permit holders and new applicants
The medical step comes earlier than many applicants expect. A new permit or CDL applicant who self-certifies as non-excepted interstate must be examined and certified before the state can post a "certified" status (383.71(h)(1)(ii)), and the state posts the certificate information it receives from FMCSA when it issues the permit (383.73(a)(7)(ii)). Before issuing the CDL itself, the state checks that the status is still "certified" (383.73(b)(3)(v)). If your first certificate is short, for example a 12-month card, it can expire between the permit and the skills test; plan training around its date. The how to get a CDL page puts the medical exam in the order of steps.
Renewing the CDL and the card
The medical certificate and the license run on separate clocks. Each time you renew the CDL you give the state your self-certification again (383.71(d)(1)), and a CDL may be issued for no more than 8 years (383.73(b)(9)), so a driver renews the medical certificate several times within one license. Renewing the card is simply another physical: there is no separate renewal form, and the new result reaches the state the same way as the first.
Checking your status
The record that counts is the medical certification status on your state driving record, which is what carriers pull and what roadside officers see. Your state licensing agency can give you a copy of your record. If your certificate was issued and the state record still shows "not certified" after a few days, contact the examiner first (to confirm the result was transmitted) and then the state.
Changing your self-certification
Moving from interstate to intrastate, or the reverse, is a state transaction: you file a new self-certification with the licensing agency. California, for example, requires a new self-certification form at a field office and a corrected license. If you change to non-excepted interstate, you must be medically certified before you drive interstate.
Common mistakes
- Relying on a grace period. The 10 and 60-day figures are deadlines for the state, not permission for you to drive.
- Choosing intrastate to skip the physical, then driving interstate. An interstate trip on an intrastate self-certification leaves you unqualified.
- Assuming the old card survives a failed exam. It does not, under 391.43(g)(3).
- Leaving the variance letter at home. It is the one document you must still carry.
- Booking the renewal for the expiry date. Book a few weeks ahead so a 45-day pending decision does not leave you uncertified.
Examiners on the National Registry are listed by town in the DOT physical directory.