What Triggers an FMCSA Audit?
FMCSA may initiate a compliance review based on several factors:
- High Out-of-Service Rate — Roadside inspections revealing safety violations
- Poor Safety Score — Elevated CSA (Compliance, Safety, Accountability) scores
- Serious Accident — Fatal or major crashes involving your vehicles
- Complaint Investigation — Reports from drivers, competitors, or the public
- New Entrant Audit — Required within 18 months of receiving operating authority
- Random Selection — Targeted enforcement initiatives
FMCSA Compliance Review Categories
| Inspection Area | Key Documents Reviewed | Common Violations |
|---|---|---|
| Driver Qualification | DQ Files, medical certificates, MVRs | Expired medical cards, missing files |
| Drug & Alcohol Testing | Testing records, MRO reports, consortium agreements | Missing random tests, no program |
| Hours of Service | ELD records, driver logs, supporting documents | Falsified logs, excessive hours |
| Vehicle Maintenance | Inspection reports, repair records | Missing inspections, unsafe vehicles |
| Accident Register | Accident files, reportable crashes | Incomplete documentation |
| Insurance | Certificates of insurance, MCS-90 endorsement | Lapsed coverage |
Medical Certification Audit Checklist
The driver qualification portion of an FMCSA audit includes intensive review of medical certifications. Ensure you have:
- ☐ Current Medical Examiner’s Certificate (MCSA-5876) for every driver
- ☐ Medical certificates issued by examiners on the National Registry [3]
- ☐ Expiration dates clearly visible on all certificates
- ☐ Medical Examination Reports (MCSA-5875) on file — recommended
- ☐ Skill Performance Evaluation (SPE) certificates for drivers with limb impairments
- ☐ Diabetes exemption documentation (MCSA-5870) for insulin-treated drivers
- ☐ Vision exemption documentation if applicable
- ☐ Proof of electronic medical certification transmission (after June 2025)
FMCSA Audit Outcomes
Following a compliance review, FMCSA assigns a safety rating [4]:
| Rating | Meaning | Consequences |
|---|---|---|
| Satisfactory | Adequate safety management controls | No action required |
| Conditional | Safety management controls inadequate | Must correct deficiencies |
| Unsatisfactory | Inadequate controls or pattern of non-compliance | May be subject to out-of-service order |
| Unrated | No compliance review completed | Subject to New Entrant audit |
How to Prepare for an FMCSA Audit
- Audit Your Own Files First — Review every DQ File for completeness
- Verify All Medical Certificates — Check expiration dates and ensure certificates are from National Registry examiners
- Update Expired Cards Immediately — Schedule DOT physicals for any driver with expired or expiring certificates
- Review Drug Testing Records — Confirm all required tests are documented
- Organize Documentation — Create consistent file structure for all drivers
- Train Your Staff — Ensure personnel understand compliance requirements
- Document Everything — Maintain records of your compliance efforts
Charlotte DOT Exam Center Audit Support
We help Charlotte-area motor carriers maintain audit-ready status:
- Properly Formatted Documentation — MCSA-5875 and MCSA-5876 forms that meet FMCSA requirements
- Electronic Registry Submission — Immediate upload to FMCSA National Registry
- National Registry Verification — Our examiners’ credentials are verifiable
- Expiration Tracking — Fleet accounts receive renewal reminders
- Same-Day Certification — Rapid processing to close compliance gaps
Frequently Asked Questions
How much notice does FMCSA give before an audit?
FMCSA typically provides advance notice for scheduled compliance reviews, usually 2-4 weeks. However, investigators may conduct unannounced “focused” reviews in response to complaints or accidents. New entrant safety audits are generally scheduled in advance.
What if a driver’s medical certificate expires during an audit?
Any driver operating with an expired medical certificate is an immediate violation. The driver must be placed out-of-service until they obtain a valid certificate. This violation will be documented in the audit findings.
Can I fix violations discovered during an audit?
FMCSA documents violations as of the audit date. While you can and should correct deficiencies immediately, the violations themselves remain in the compliance review record. Demonstrating immediate corrective action may influence the final safety rating determination.
How often should I conduct internal audits?
Best practice is to conduct quarterly internal audits of Driver Qualification Files and monthly reviews of medical certificate expiration dates. This proactive approach ensures you’re always audit-ready.
Get Audit-Ready Today
Charlotte DOT Exam Center
8415 Pineville-Matthews Road, Suite 102
Charlotte, NC 28226
Phone: 704-544-3494
Email: appt@tebbyclinic.com
References
- [1] FMCSA. Compliance Review Fact Sheet. FMCSA.dot.gov
- [2] FMCSA Civil Penalty Schedule. FMCSA.dot.gov
- [3] FMCSA National Registry of Certified Medical Examiners. nationalregistry.fmcsa.dot.gov
- [4] 49 CFR Part 385 – Safety Fitness Procedures. eCFR.gov
