NEMT DOT Physical in 2027: When Drivers Need a Medical Card and How to Track It

When federal rules require a DOT physical

A DOT physical is the medical exam in 49 CFR part 391. A driver it covers may not drive until a medical examiner certifies them as physically qualified (49 CFR 391.41). The federal physical rules reach a NEMT driver only when both of these are true.

1. The vehicle is a commercial motor vehicle. Under 49 CFR 390.5T, that means a gross vehicle weight rating or actual weight of 10,001 pounds or more, or a vehicle designed or used to carry more than 8 people, driver included, for compensation. The weight rating is the GVWR, set by the maker.
2. The trip is interstate. It crosses a state line, passes through another state, or is the in-state part of a trip that starts or ends in another state.

A sedan, minivan, or small wheelchair van on in-state trips meets neither test. Its driver needs no federal medical card, though a state or contract may still ask for one.

The 9 to 15 passenger van exception

On an interstate trip, a van built or used for 9 to 15 people and under 10,001 pounds is a commercial motor vehicle when it carries people for pay. But 49 CFR 390.3T(f)(6) drops most federal rules, including the physical, when the van is not used for direct compensation. FMCSA defines direct compensation as payment to the carrier by the passengers, or someone acting for them, for the ride itself.

FMCSA’s guidance in Appendix A to part 390 (as amended April 30, 2026) gives an example: a camp that collects a specific fee for transportation receives direct compensation and loses the exception. If you are paid a fee for each ride, plan on the full rules for those vans on interstate trips.

The sick and injured exception

The federal safety rules also except “the transportation of human corpses or sick and injured persons” (49 CFR 390.3T(f)(4)). The rules do not define the phrase, and the FMCSA inspection rules guide covers one FMCSA letter on it. Do not count on it for routine NEMT trips without FMCSA’s answer for your own operation. Call FMCSA at 800-832-5660 and ask for the answer in writing.

The DOT number guide covers registration and operating authority for the same vehicles, and rural NEMT covers driving hours.

CDL drivers and the medical card

A vehicle designed for 16 or more people, driver included, needs a driver with a CDL even on in-state trips. The CDL guide explains the vehicle lines and the passenger endorsement.

Every CDL driver tells the state which of four kinds of driving they do (49 CFR 383.71(b)(1)), and the answer decides the medical card:

• Non-excepted interstate. Interstate driving under the federal driver rules. A medical card is required.
• Excepted interstate. Interstate driving only in operations the federal rules except. No federal medical card.
• Non-excepted intrastate. In-state driving only. Your state’s driver qualification rules decide.
• Excepted intrastate. In-state driving only, in operations your state excepts.

Since June 23, 2025, the examiner’s result for a non-excepted interstate driver reaches the state electronically through FMCSA, and the state posts the status on the driver’s record (49 CFR 383.71(h)). CDL and permit holders with a current card no longer have to carry it (49 CFR 391.41(a)(2)). Before such a driver drives for you, pull the CDLIS driving record from the state and note the driver’s self-certified type and medical status in their file (49 CFR 391.23(m)(2)). A non-excepted interstate CDL holder with no medical status on that record is “not-certified” for interstate driving (49 CFR 391.51(b)(6)).

State and contract rules that require a physical

Some states and Medicaid contracts require an exam even for drivers the federal rules skip. Here is who each covers and what it asks for.

State and rule	Who it covers	What it requires
Alabama (PSC rules, revised June 13, 2022)	Drivers for in-state for-hire passenger carriers under PSC rules	A DOT medical certificate from the past 24 months, carried while driving, with a copy on file
California (22 CCR 51231.2)	Medi-Cal wheelchair van drivers and attendants	A physical exam within the past 2 years on DMV form DL-51
Connecticut (DMV, as of October 2026)	Drivers applying for a public passenger endorsement	An exam by a National Registry examiner within 90 days before applying
Minnesota (MnDOT, October 2025)	For-hire special transportation service, and for-hire vehicles for 8 or more	A medical examiner’s certificate, good up to 2 years, carried unless the driver has a CDL
New York (DMV CDL-15, February 2026)	Ambulette drivers under Article 19-A, the bus driver law	An exam before hire on form DS-874 or MCSA-5875, then at least every 2 years
Ohio (OAC 4766-3-13, June 15, 2022)	Drivers for licensed ambulette services	A signed fitness statement from a physician, nurse practitioner, or physician assistant, or a DOT physical
Tennessee (TennCare contract, July 1, 2026)	Every driver giving TennCare NEMT rides	An exam before service at least as extensive as the FMCSA exam, and again when needed, such as after a stroke

A few of these carry extra steps:

• New York. The examiner cannot be the driver’s own health care provider, and chiropractors are not accepted. A diabetic driver also needs a DS-704 certification from their own provider every 6 months. See the New York NEMT guide.
• Tennessee. Proof of each exam stays in the driver file for unscheduled audits, with an attestation signed by the driver that gives the exam’s effective dates. See the Tennessee NEMT guide.
• Connecticut. A driver without a CDL uploads the certificate to the DMV’s medical portal, cdlmedcert.ct.gov, instead of sending it with the application. See the Connecticut public passenger endorsement.
• Minnesota. The driver gives a copy to the provider that employs them. The Minnesota NEMT guide covers the rest of the special transportation service rules.

Brokers can add their own rule. In eastern Kentucky, Sandy Valley Transportation Services requires a Department of Transportation physical before a driver works in the state’s human service transportation program. MTM Health asks for a statement instead: in its standard provider agreement, in the January 1, 2023 version Pennsylvania posts, submitting a driver for credentialing is your representation that the driver has said they have no known physical or mental impairment that would prevent safe driving. The driver requirements guide compares those rules.

What happens at a DOT physical

The exam must be done by a medical examiner on the FMCSA National Registry of Certified Medical Examiners (49 CFR 391.43). FMCSA says that includes medical doctors, doctors of osteopathy, physician assistants, advanced practice nurses, and chiropractors. Use the registry’s search to find one near you before you send a driver.

The examiner records the results on form MCSA-5875 and, if the driver qualifies, issues the medical examiner’s certificate, form MCSA-5876. For a driver who needs no CDL, the examiner gives the original to the driver and a copy to you on request. Among the standards in 49 CFR 391.41(b):

• Vision. At least 20/40 in each eye and both eyes together, with or without glasses, a 70 degree field of vision in each eye, and the ability to tell red, green, and amber signals apart.
• Hearing. Hearing a forced whisper at 5 feet in the better ear, with or without a hearing aid, or passing an audiometer test.
• Medical conditions. No condition likely to cause loss of consciousness or control, such as epilepsy, and no heart, lung, blood pressure, or other condition likely to interfere with safe driving.
• Diabetes and medicines. Insulin-treated diabetes is allowed under the separate standard in 49 CFR 391.46. Schedule I drugs are never allowed. Other controlled substances are allowed only when prescribed by a practitioner who knows the driver’s history and advises they will not affect safe driving.

Drug and alcohol testing is a separate program with its own rules. See NEMT driver drug testing.

How long the card lasts

A card lasts up to 24 months (49 CFR 391.45). The examiner may issue it for less to watch a condition such as high blood pressure. Two groups need an exam every 12 months: drivers with insulin-treated diabetes and drivers who qualify under the alternative vision standard. Any driver whose ability to drive is impaired by an injury or illness must be examined again.

Since June 23, 2025, a “not qualified” finding cancels every card the driver held before (49 CFR 391.43(g)(3)). The examiner can also hold a decision for up to 45 days while waiting for more information.

Who pays for the exam

Paying for it yourself is the safest choice. California bars employers from making applicants or employees pay for a required pre-employment physical, or for any exam a law or regulation requires (Labor Code 222.5). Under the federal minimum wage law, an employer-required physical cannot cut into a worker’s minimum wage or overtime (DOL Fact Sheet 16, revised July 2009).

Can you require a physical when no rule does?

You can, if you follow the ADA’s order. An employer may require a medical exam after making a job offer and before the job starts, and may make the offer depend on the result, if every new hire in that job takes the same exam (29 CFR 1630.14(b)). Results go in a separate, confidential medical file, not the personnel file.

Two limits apply:

• Current drivers. An exam of someone already working for you must be job-related and consistent with business necessity (29 CFR 1630.14(c)). A return-to-work exam after an illness that affects driving is one example.
• Screening someone out. If an exam result leads you to reject a driver, the reason must be job-related and consistent with business necessity, and the job must not be possible with a reasonable accommodation. Where a federal rule requires the result, that rule is a defense (29 CFR 1630.15(e)).

The ADA covers employers with 15 or more employees (29 CFR 1630.2(e)). State laws can reach smaller companies, so check yours before you write the policy.

How to track medical cards and expiration dates

A lapsed card means a driver who cannot legally take a covered trip. Build the check into hiring and into a monthly routine.

1. Collect the card before the first covered trip. File the original or a copy, with any medical variance it relies on (49 CFR 391.23(m)(1)).
2. Check the examiner on the National Registry as of the card’s issue date. For a driver without a CDL, keep a note of that check in the driver file (49 CFR 391.51(b)(8)).
3. For CDL drivers, pull the CDLIS driving record and note the self-certified type and medical status (49 CFR 391.23(m)(2)).
4. Record the expiration date the examiner wrote, not 24 months from the exam. Examiners can issue shorter cards to drivers with a condition they want to watch.
5. Set reminders 60 and 30 days ahead, and book the exam before the card runs out.
6. Pull a driver off covered trips the day a card expires, and after any illness or injury that affects driving until a new exam clears them.
7. Keep the records. A federal driver file stays for the length of employment plus three years, and each card can be removed three years after it was issued (49 CFR 391.51). New York’s Article 19-A rules keep physicals for 3 years plus the current year.

The driver file checklist has lines for the medical examiner’s certificate and its renewal, next to the license, driving record, and training records.