The Owner-Operator Independent Drivers Association is backing an exemption request that would allow drivers to continue using paper copies of their medical certification.
In June 2025, the Federal Motor Carrier Safety Administration announced it would be implementing the Medical Examiner’s Certification Integration Rule. Commonly known as NRII, and originally published in April 2015, the final rule requires medical examiners to electronically submit results from medical certification exams to the FMCSA and state licensing agencies. Additionally, the new electronic system would also eliminate the need for truckers to carry a paper copy of their certification.
Since the agency announced the rollout of the new regulations, some states have struggled to fully implement NRII, prompting FMCSA to issue a series of waivers that allow drivers to continue relying on paper medical cards to demonstrate compliance.
Despite the agency’s best efforts to accommodate drivers, many have still had issues in states that have not yet implemented the new rule.
This past December, the Commercial Vehicle Safety Alliance petitioned the agency to issue guidance to commercial motor vehicle enforcement officials stating that paper copies of exams are permitted to demonstrate medical certification.
In its letter, CVSA noted that even carriers in states where the new regulations were fully implemented were experiencing issues with “reliable transmission of driver medical certification information” due to “incompatibility and errors being made in the data exchange” between medical examiners, state driver’s license agencies, and FMCSA.
“Motor carriers continue to grapple with the effects of this partial implementation of the NRII requirements,” CVSA said. “Currently, if a motor carrier has a driver whose medical certificate is not transmitting in the system correctly, they are forced to either temporarily cease using that driver until the issue is resolved or resubmit them for an additional medical certification exam, to ensure that they can prove the driver is qualified.”
In response to the group’s letter, FMCSA said it was unable to issue the guidance requested “because it would conflict with the regulations currently in effect, which are binding on regulated entities.” Because of this, the agency treated the group’s request as an application for exemption and opened a 30-day public comment period, which closed on March 9.
In total, the FMCSA received nine comments on the exemption request, all in support of granting it. Among those were comments filed by OOIDA, which said that granting the request would “achieve an equivalent level of safety” to that of the NRII system.
“No driver who has been medically cleared should be forced off the road due to external processing errors,” the Association said in its letter signed by President Todd Spencer. “We urge the agency to grant the exemption allowing motor carriers and drivers to rely on a paper copy of the MEC until all states are fully compliant with the NRII final rule.”
States have been given ample time to implement the new medical certification rules.
Since its publication, the final rule’s provisions have been delayed twice – once in June 2018 and again in April 2021 – postponing the compliance date to June 23, 2025. Despite the rule being published a significant time ago, some states still struggled to meet the summer deadline.
Those delays prompted FMCSA to issue a waiver in July 2025, allowing drivers to continue using a paper copy for up to 15 days after the exam date. The next month, the agency modified the waiver to allow the use of a paper copy of the medical certification for up to 60 days after the exam.
The waiver has since been extended twice – once in October and again last month – with five states yet to fully implement the new regulations. Those states are Alaska, California, Kentucky, Louisiana and New Hampshire. The current waiver is set to expire on April 10. LL
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