The 2024 Driver Qualification File Checklist You Need to Pass a DOT Audit

[Updated March 2023]

Want to print out the DQ File Checklist? Download the free PDF by clicking below: 

Think about the last time one of your drivers had an accident. 

After making sure everyone is OK, you quickly go look at the Driver Qualification File to make sure everything is in order. Why? Because you know if someone gets lawyered up, you need to quickly prove everything is in compliance. Plaintiff attorneys want easy money and cases they can win. Prove to them early on that you're going to be a tough nut to crack, and they'll move on to an easier victim. 

We have a two-part combination that can help you avoid unnecessary court appearances: this simple checklist and technology to automate the communication and document uploads from your drivers. You can save time and money while sleeping soundly at night because you know you’re in compliance.

This checklist is a summary from FMCSA 391. It’s designed to help you ensure no detail is missed when you’re creating DQ files.

Employment Applications

• Driver’s name, date, and signature
• Name and address of the Employing Motor Carrier
• Driver’s date of birth and SSN (SSN not needed if religious practices indicated)
• 3 years of residence history without gaps
• 3 years of previous employment plus up to an additional 7 years (total of 10) if the driver worked in a safety-sensitive position
  • Each employer includes: 
    • Company name
    • Address
    • Supervisor 
    • Contact information
    • Reason for leaving
      
  • Any gaps in the employment history greater than 30 days need to be explained

• Current license information for each active license:
  • Issuing state
  • Number
  • Expiration on each unexpired commercial license 
  • Driver must note if any license was suspended, revoked, or forfeited within the past 3 years
    
• Driving experience and type of equipment 
• 3-year driving history of violations and suspensions 
• Hours worked last eight days before hire

Pre-Hire Motor Vehicle Report (MVR)

• The Motor Vehicle Report covers the most recent 3-year period (in every state that driver held a license in the past 3-year period).
• MVR order date is within 30 days of a driver’s official date of hire.
• If a driver is not hired within that period of time, you must run a new MVR before the driver is permitted to drive.
• Confirm your Compliance Management System provides a timestamp for when a company employee reviews the results.

Previous Employment Verification

• Any safety-sensitive positions a driver has held over the past 3 years must be verified. If you are unsure if a previous employer was a safety-sensitive position or not, always err on the side of caution.
• Ask and document the DOT-mandated questions about a driver’s history of drug and alcohol testing:
• Were they in a safety-sensitive position?
  • If so, were they drug tested?
    • Did they test positive?
    • Did they refuse to be tested?
    • Did they have other DOT test violations?
    • Did they report any outside drug/alcohol violations to you?
• Document a “good faith” effort for each previous employer
  
  • “Good faith” is subjective, so our best practice is three separate phone calls and follow-up email/fax for written documentation.
  • Document the evidence in your Applicant Tracking System.
  • Reporting employers must sign and date the Employment Verification request and send it back within 30 days of receiving
  • Complete documented efforts before 30 days from the date of hire

Road Test Certificate

• If the road test is successfully completed, the person who gave it shall complete a driver's road test certificate that is signed and dated by the driver and trainer completing the road test.
• A copy of a current and valid CDL can be used in lieu of the Road Test.
• Review your company’s policy and your state’s individual rules regarding road testing–they may be more demanding than the DOT. Many states, for example, require occasional road tests to track driver skills over time.
• If your company runs your own initial road tests, or a driver has a road test conducted at a third-party site (not the BMV), you must retain this documentation in the DQ folder.
• Important note: As of March 22, 2022, the road test certificate no longer needs to capture a driver’s:
  • Social Security number
  • Driver’s license number
  • Licensing state

Commercial Driver’s License (CDL)

• Non-expired CDL with proper endorsements and class
• Scan both sides of a CDL (if your state has endorsements or restrictions on the back)
• Drivers may only have one valid CDL at a time (unless they are granted a special exemption from the DOT, which you need to keep in the DQ folder as well)
• It is a good practice to retain the original CDL of a driver in the DQ folder for as long as the driver is employed with your company to prove you did your due diligence before onboarding.
• Non-CDL drivers should also have their valid (not expired) state driver’s license on file with appropriate endorsements if applicable.

Medical Card/Medical Examiner’s Certificate

• Complete DOT-approved physicals no less than every two years and more frequently if a physician deems it necessary. 
• The physician must completely fill out and sign a Medical Examiner’s Certificate (commonly known as a Med Card). No fields can be left blank.
• The doctor conducting the physical must be in the National Registry and can be searched with the registry number on the Med Card. Some states have restrictions such as not allowing chiropractors to qualify, even if they are in the registry.
• The driver must sign and complete the bottom section of the Med Card.
• The accompanying physical exam documentation (long form), as well as exemptions and waivers, must be stored in a driver’s separate Medical folder unless state law dictates otherwise.
• Add to your checklist state’s laws for any special waivers.
• Non-CDL drivers must still have physicals conducted if they are interstate drivers (i.e. they cross state lines).
• Drivers who drive in excepted interstate/intrastate are not required to have DOT physicals conducted. You must still have a waiver in their DQ file stating this.

Annual MVR

• MVRs should be run at least once a year starting on day 365 after the hire date.
• MVR should contain all recent driver history and up-to-date medical information for that driver.
• MVR should contain the correct self-certification for the driver. Consult the full DOT descriptions for each of the four categories of drivers if you aren’t sure how certain drivers should self-certify with the state licensing agency.

Certificate of Violations

• Prior to May 9, 2022, at least once every 12 months, drivers were to submit a list of all convicted violations of motor vehicle traffic laws and ordinances during the previous 12 months. Click here for more information on this rule change. 
• Carriers were to review this and compare it to the driver’s annual MVR, typically during the driver's Annual Review. 
• As of May 9, 2022, the requirement is now eliminated.
• Motor carriers must retain all COVs obtained before May 9, 2022, in the DQ File for 36 months from the document date.

Annual Review

• The Annual Review is held at least every 12 months between both the driver and the manager.  The manager is to review the MVR to determine whether the driver still meets the minimum requirements for safe driving, and to confirm they are not disqualified pursuant to 49 CFR 391.15. 
• Ideally, a new Annual MVR should be completed the same day as the Annual Review.  Prior to May 9, 2022, a driver-supplied Certificate of Violation was also used to complete the Annual Review.
• Managers must sign and date the Annual Review document on the same day.
• The Annual Review should list all of the violations (regardless of vehicle type or ownership) a driver had in the past year that are on the MVR. It should also include out-of-state violations reported by the driver.
• If a driver had no violations, this must be indicated on the form. Most DOT-approved forms have a box to check for no violations.

Disclosure and Authorization Forms

• The DOT requires drivers to receive a document that lists all of the inquiries that will be made. This must be signed and dated and in the file.
• Inquiries fall under the four major categories of employment history (both previous employment for safety-sensitive purposes and also for character and work experience); personal history (residence verification, credit/financial history, and Social Security verification); criminal background check, and driving history.
• These forms may be combined into one document or be several separate documents. However, each one must be signed and dated by the driver and must be separate from the application.

Other Record Types

There are several other records you will or may have to collect during a driver’s hiring process. Some of these, such as the criminal background check, typically are stored in separate paperwork from the Driver Qualification folder in a distinct HR folder.

With software systems, you can automate the folder labeling of these kinds of documents, as well as training documents, in a separate folder. Others, such as drug and alcohol test results, must be kept separate in their own specific folder per DOT rules for privacy and legal reasons. Compliance Management Systems make it easy to create permissions to control who can see what record type. 

We can help you interpret the DOT regulations and your state’s regulations regarding some of these specific records in order to make the best decisions regarding how to organize these other record types. 

However you choose to organize your records, never show an auditor more than he/she asked for.

Rehired Drivers

Rehired drivers (who have left the company for more than 30 days) must have a new and separate DQ File created upon their return to your company. This requires new documentation for all pre-hire records.

You may use a valid CDL in lieu of a road test. You can build on any successfully conducted Verification of Employment during the original screening process and then conduct verifications for any period since leaving your organization. In addition, drivers who left the company for more than 30 days must undergo a new drug test.

Non-DQ Records

In addition to these necessary items for your driver qualification files, you will also want to have the following critical items accounted for as they can be requested during an audit:

• An up-to-date copy of FMCSA regulations
• MCS 90 form with your current liability insurance
• Drug and Alcohol Testing paperwork, including your company policy and testing procedures, all driver pre-employment test results, and an up-to-date summary of the past calendar year of random tests
• 6 months of all driver logs
• Complete maintenance records, including 14+ months of annual inspections for all commercial vehicles in operation and 90 days of post-trip inspection reports for any vehicles with issues or defects
• A current DOT security plan
• Drug and alcohol training materials and policies with a signed driver receipt for them (from before hire)
• A current and up-to-date accident file
• Documented policies for hiring, discipline, and removal/reinstatement of unqualified drivers from service

Additional Documentation

Depending on your industry, vehicles, drivers, etc. some additional documents may be needed including:

• Entry-Level Driver Training Certificate
• Longer Combination Vehicle (LCV) Driver Training Certificate
• Longer Combination Vehicle (LCV) Certificate of Grandfathering
• Multiple-Employer Drivers
• Skill Performance Evaluation Certificate

Common Questions Related to a DOT Audit

Q: What is a DOT audit?

A: A DOT audit is an investigation conducted by the Department of Transportation. The goal of an audit is to determine if a carrier is complying with federal transportation laws. There are three types: offsite infestation, onsite focused investigation, and onsite comprehensive investigation.

Q: Why might you be audited?

A: There are several “triggers” that can lead to a DOT audit. The five most common are:

1. High CSA scores
2. Crashes
3. Roadside Out-of-Service Violations
4. Failing a new entrant audit
5. Complaints submitted to the FMCSA

Q: How should you prepare for an audit?

A: You could write a whole book on this one. I recommend you check out our ultimate guide on preparing for DOT audits. It’s a free resource.

Q: What happens if you fail a DOT audit?

A: You’ll usually get your audit results within 45 days. If you fail, you’ll receive a detailed explanation as to why and the steps you need to take to correct the issue. Then, you’ll need to create your plan. This is called a Corrective Action Plan (CAP). You’ll send your CAP to the FMCSA within the number of days specified, and then implement it before you’re audited again.

Q: What is a DQF?

A: DQF stands for driver qualification file. DQFs are record-keeping requirements mandated by the Federal Motor Carrier Safety Administration (FMCSA). Trucking companies must meet these requirements for their employed drivers.

Q: Who needs a DQF?

A: All drivers operating the following vehicles need a DQ File:

• A commercial motor vehicle (CMV) with a gross vehicle weight (GVW) or gross vehicle weight rating (GVWR), or gross combination weight (GCW) or gross combination weight rating (GCWR) of 10,001 pounds or more.

Q: How should you store DQFs?

A: DQ Files are best stored online in a secure location. Some companies keep paper copies, but this often leads to lost/missing files and extra work. The FMCSA has increased its off-site audits by 8,485% from 2017 to 2021. This means you’re going to need digital copies of your DQ Files to upload into their portal.

Q: What happens if the driver qualification file basics are not maintained?

A: At the very least, you’ll be fined. At worst, you could be out of business. It depends on the file type, how many offenses you have, and a whole host of other factors. The easiest thing to do is just make sure you’re never missing a file.

Don’t Be Afraid of Plaintiff Attorneys

Managing this checklist for your fleet is a taxing process. Use A-Suite Comply to automate collecting, building, and tracking your DQ files. Get back to more important tasks than paper-pushing by trying A-Suite Comply for free today!