📋 Key Takeaways About Driver Qualification File Requirements
- What’s required: Application, MVR inquiry, road test certificate, Medical Examiner’s Certificate (MCSA-5876), annual driving record review, previous employer investigation
- Important: Only the MCSA-5876 (medical card) goes in the DQ file—keep the MCSA-5875 (exam report) in a separate confidential medical file
- Retention: Maintain while employed, then retain 3 years after employment ends
- Penalty: Each missing document can result in fines from $1,270 to $16,864 per violation
- Deadline: Previous employer investigations must be completed within 30 days of hire
What Is a Driver Qualification File?
A Driver Qualification File (DQ File) is the collection of documents that motor carriers must maintain for every driver who operates commercial motor vehicles (CMVs) as required by 49 CFR 391.51 [1]. The DQ File proves that each driver meets FMCSA’s minimum qualifications including age, experience, physical fitness, driving record, and road test competency. FMCSA auditors review DQ Files during compliance investigations, and missing or incomplete files result in violations with fines up to $16,864 per offense [2].
At Charlotte DOT Exam Center, we provide properly formatted medical documentation that meets DQ File requirements. Our Medical Examination Reports (MCSA-5875) and Medical Examiner’s Certificates (MCSA-5876) are audit-ready for your records.
Required Documents in a Driver Qualification File
FMCSA requires the following documents in every DQ File [1]:
| Document | Requirement | Retention Period |
|---|---|---|
| Driver’s Application for Employment | 49 CFR 391.21 | 3 years after employment ends |
| Motor Vehicle Record (MVR) Inquiry | 49 CFR 391.23 | 3 years after employment ends |
| Previous Employer Safety Performance History | 49 CFR 391.23(d) | 3 years after employment ends |
| Road Test Certificate (or equivalent) | 49 CFR 391.31 | 3 years after employment ends |
| Medical Examiner’s Certificate (MCSA-5876) | 49 CFR 391.43 | 3 years after employment ends |
| Annual MVR Review | 49 CFR 391.25 | 3 years after employment ends |
| Annual Driver’s Certification of Violations | 49 CFR 391.27 | 3 years after employment ends |
Medical Documentation Requirements
The medical component of the DQ File requires specific attention. Motor carriers must maintain:
Medical Examiner’s Certificate (MCSA-5876)
The MCSA-5876 (commonly called the “DOT card”) must be current in the DQ File. Certificates are valid for up to 24 months, though drivers with certain medical conditions receive shorter certification periods [3]:
- 24 months — Healthy drivers with no disqualifying conditions
- 12 months — Drivers with Stage 1 hypertension, well-controlled diabetes
- 3-6 months — Drivers with Stage 2 hypertension requiring monitoring
- Annual recertification — Insulin-treated diabetes mellitus (ITDM)
Medical Examiner’s Certificate Query (after June 2025)
Effective June 23, 2025, motor carriers must query the FMCSA database to verify driver medical certification status [4]. The electronic submission mandate eliminates reliance on paper certificates alone.
Common DQ File Violations
| Violation | CFR Reference | Severity |
|---|---|---|
| No medical certificate in file | 391.51(b)(7) | Critical |
| Expired medical certificate | 391.45(b) | Critical |
| No annual MVR review | 391.25(a) | Acute |
| Incomplete employment application | 391.21 | Acute |
| No road test certificate | 391.31(a) | Critical |
| Missing previous employer investigation | 391.23(d) | Acute |
DQ File Checklist for Charlotte Employers
Use this checklist to ensure your Driver Qualification Files are audit-ready:
- ☐ Driver’s application for employment with 3-year work history
- ☐ Verification of previous employer safety performance (within 30 days of hire)
- ☐ Motor vehicle record from state DMV
- ☐ Road test certificate OR copy of CDL (if CDL substitutes)
- ☐ Current Medical Examiner’s Certificate (MCSA-5876)
- ☐ Copy of Medical Examination Report (MCSA-5875) — recommended
- ☐ Annual MVR review with date and reviewer signature
- ☐ Annual driver’s certification of violations
- ☐ Entry-level driver training certificate (for CDLs issued after February 7, 2022)
How Charlotte DOT Exam Center Supports Your DQ Files
Every DOT physical examination at our facility includes:
- MCSA-5876 (Medical Examiner’s Certificate) — Laminated card for the driver + copy for employer
- MCSA-5875 (Medical Examination Report) — Complete examination record for your files
- Electronic submission to FMCSA — Immediate upload to National Registry database
- Proper date formatting — Expiration dates clearly noted
- Examiner credentials documented — National Registry number included
Frequently Asked Questions
How long must DQ Files be retained?
DQ Files must be retained for 3 years after a driver’s employment ends. The medical certificate specifically must be kept for 3 years from the date it was issued or 3 years after employment termination, whichever is longer [1].
Do owner-operators need to maintain DQ Files?
Yes. Owner-operators who are self-employed must maintain their own DQ File containing all required documents. FMCSA auditors will request this documentation during compliance reviews regardless of company size.
What’s the penalty for incomplete DQ Files?
Penalties for DQ File violations range from $1,270 to $16,864 per violation depending on severity. Critical violations (like missing medical certificates) carry the highest fines and can result in out-of-service orders [2].
Should I keep the MCSA-5875 in addition to the MCSA-5876?
While only the MCSA-5876 (certificate) is technically required in the DQ File, we strongly recommend keeping the MCSA-5875 (full examination report) as well. This provides documentation of the examination findings and demonstrates due diligence during audits.
Get Audit-Ready Medical Documentation
Charlotte DOT Exam Center
8415 Pineville-Matthews Road, Suite 102
Charlotte, NC 28226
Phone: 704-544-3494
Email: appt@tebbyclinic.com
References
- [1] 49 CFR § 391.51 – General requirements for Driver Qualification Files. eCFR.gov
- [2] FMCSA Civil Penalty Schedule. FMCSA.dot.gov
- [3] 49 CFR § 391.45 – Persons who must be medically examined and certified. eCFR.gov
- [4] FMCSA. Medical Certification Electronic Transmission Rule. FMCSA.dot.gov
