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Navigating New DOT Physical Submission Requirements: What Carriers and Clinics Need to Know

June 5, 2025
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Navigating New DOT Physical Submission Requirements: What Carriers and Clinics Need to Know

As of June 23, 2025, a new federal directive will require that DOT physical exam results be submitted directly by certified medical examiners (CMEs) to the FMCSA National Registry. This change aims to streamline and standardize how states access medical certifications for commercial driver’s license (CDL) holders. While this directive marks a significant step toward centralized compliance, it is already causing confusion across state lines as some jurisdictions begin early enforcement.

The Transition: Electronic Over Walk-In

Historically, many states allowed CDL holders to present a copy of their DOT physical certificate directly to their local Department of Motor Vehicles or licensing authority. However, under the new mandate, states will only accept certifications transmitted electronically through the FMCSA’s National Registry system. This has effectively eliminated the ability for drivers to "walk in" and submit physicals manually in certain states—Missouri being a recent example.

One recent case involved a driver who attempted to update their CDL in Missouri using a valid physical taken through a compliant clinic. The state rejected the in-person submission, citing the new requirement for electronic transmission by the CME. Such incidents underscore the urgency for carriers and clinics to understand and comply with the updated process.

Integrated Care's Current Compliance Status

Integrated Care, LLC is already positioned to meet these requirements. All DOT physicals conducted under our program are being submitted through the National Registry portal. Our certified medical examiners are active within the Registry, ensuring that submissions are both compliant and trackable by state licensing agencies.

Still, as implementation varies by state and occasional system inconsistencies arise, we remain committed to verifying every submission and assisting clients whose drivers encounter issues.

Communication Challenges with Regulatory Bodies

Despite best efforts by compliant clinics and carriers, navigating communication with federal and state agencies remains difficult. As one industry professional noted, “It is difficult to influence the Federal and State government. They don’t make it easy to communicate or explain.” This frustration is shared across the transportation sector and highlights the need for clearer guidance and responsive systems during such transitions.

What Carriers Should Do Now

  • Verify CME Registration: Ensure your DOT physicals are conducted by CMEs listed on the FMCSA National Registry.
  • Confirm Submission: Ask for confirmation that physicals have been electronically submitted to the FMCSA.
  • Educate Drivers: Let drivers know they may no longer be able to walk in to update their CDL with a printed physical.
  • Monitor State-Specific Changes: Not all states may adopt the new system on the same timeline; staying informed can prevent surprises.

Looking Ahead

Integrated Care will continue monitoring this transition and updating partners as needed. While the goal of this policy is improved efficiency and accountability, the implementation phase will likely include growing pains. By working together and maintaining open communication, we can reduce friction and ensure drivers remain compliant and on the road.

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