Do CDL drivers still need a paper medical card in the DQ file?

For interstate CDL drivers, the medical certification status now appears on the CDLIS motor vehicle record the carrier obtains, and FMCSA treats that record as satisfying the medical certificate requirement in the DQ file. Many carriers still keep a copy of the medical examiner's certificate as a backup and for the first 15 days after an exam. Non-CDL drivers still need the certificate itself in the file. Verify against the current text of 49 CFR 391.51.

How often do I need to pull a motor vehicle record?

At hire, an MVR from every state where the driver held a license in the past three years, and then at least once every 12 months for the ongoing annual review of driving record under 49 CFR 391.25.

How long do I keep a driver's DQ file after they leave?

The driver qualification file must be kept for the period of the driver's employment plus three years after the driver leaves. Some individual records, like the annual MVR and annual review, are kept as the most recent copy plus the prior three years.

Does holding a CDL replace the road test?

In most cases a carrier may accept a valid CDL in place of the road test and certificate under 49 CFR 391.33, with exceptions such as drivers of double and triple trailers or tank vehicles. Check the current rule for the vehicle type before relying on the substitution.

Driver qualification (DQ) file checklist: what every DQ file must contain

The short version

The DQ file has a fixed list of contents set by federal rule, split into hiring documents and recurring annual documents.
The recurring items — annual MVR, annual review of driving record, medical certification status — are what carriers fall behind on.
Keep the file for employment plus three years after the driver leaves.

What a DQ file is and who needs one

A driver qualification file documents that a specific driver is legally qualified to operate a commercial motor vehicle for your operation. Under federal rules you need one for every driver who operates a CMV in interstate commerce, including yourself if you are an owner-operator. The carrier is responsible for creating the file, keeping it current, and producing it on request during a compliance review or new-entrant audit.

The checklist

Hiring documents

The employment application that meets the content requirements of 49 CFR 391.21.
The motor vehicle record (MVR) obtained at the time of hiring from every state in which the driver held a motor vehicle license or permit in the preceding three years (391.23(a)(1)).
The safety performance history investigation of the driver’s previous DOT-regulated employers for the past three years, including the good-faith efforts you made to obtain it (391.23(a)(2) and related paragraphs).
The road test certificate, or a copy of the CDL or road test certificate you accepted in its place under 391.33.
The medical examiner’s certificate, or for interstate CDL drivers the CDLIS MVR showing current medical certification status.
Any medical variance the driver holds, such as a skill performance evaluation certificate or an exemption letter, if applicable.

Recurring documents

An MVR obtained at least every 12 months from each state where the driver holds a license (391.25(a)).
A signed annual review of the driver’s driving record, with the note identifying who performed it and their finding on whether the driver still meets minimum requirements (391.25(b) and (c)).
The driver’s annual list of traffic violations under 391.27, where still required. FMCSA has moved toward letting the annual MVR satisfy this; confirm the current requirement before dropping it from your process.
An updated medical examiner’s certificate or CDLIS MVR each time the driver is re-examined, so the file always reflects a current medical card.

This list covers the core, long-standing contents of 49 CFR 391.51. It is a summary, not legal advice, and federal rules change. Verify every item against the current text of 49 CFR Part 391 in the eCFR or with a DOT compliance advisor. Last reviewed September 2026.

The recurring items carriers miss

Hiring paperwork tends to get done because it is tied to onboarding. The annual items have no natural trigger, so they slip:

The annual MVR is a year old plus a few months because nobody scheduled the next pull.
The annual review of driving record exists as a spreadsheet cell but not as a signed, dated note in the file.
A driver’s medical card expired and the new one never made it into the file, or the CDLIS status was never re-checked.

How long to keep everything

The DQ file as a whole: the period of the driver’s employment plus three years after they leave.
Annual MVR and annual review of driving record: the most recent copy, plus the previous three years’ worth.
Safety performance history investigation records: three years from the date of the investigation.

What auditors flag most

An expired medical examiner’s certificate, or no current record of medical certification status.
A missing or unsigned annual review of driving record.
No MVR obtained at the time of hire, or none within the last 12 months.
No documented effort to obtain the previous-employer safety performance history.

Keeping it current without a safety manager

Most carriers running one to twenty trucks do not have someone whose job is watching these dates. The fix is a system that does it for you: every document and its expiry in one place, and a reminder before each one lapses rather than a scramble at audit time. That is exactly what Kada’s DQ file tracker does — you photograph a card, it reads the dates, you confirm, and it watches every deadline. See how the tracker works.