Can You Answer the Question FMCSA Is Asking?

June 23, 2026

Students walking in the training yard

What auditors are really asking for is the proficiency story.

The Certificate Is Not the Whole Story

When an auditor shows up at your school, they aren't going to ask how many students you graduated last year. They're going to pull up the TPR student file and ask you to show them how you knew that particular student was proficient before you certified him. If your answer is the completion certificate itself, you’ve got the last back cover of the book but are missing the rest. This is where we have seen the biggest gap for training providers.

What auditors are really asking for is the proficiency story. Not just whether the student finished, but how they got there: where they started, what skills they struggled with, what improved, who verified it, and when they finally performed each required skill to standard. If that story is not in the file, the school may have made the right call, but it has no way to prove it later.


Why the Rule Focuses on Proficiency

It helps to remember why the rule reads the way it does. When FMCSA wrote the entry-level training requirements, it declined to set a minimum number of behind-the-wheel hours. People still get tripped up by that. They assume "no minimum" means get them in and out as fast as possible, when it means almost the opposite. The agency decided hours were the wrong thing to count, and what it wants instead is proof that the student can actually do the job, demonstrated and documented by the instructor before any student can graduate.

So picture that file on the table again. A completion certificate tells the auditor that the student reached the end of your course. It tells them nothing about whether he could back into a tight dock, hold his space in traffic, or recover when something went wrong on the road. It doesn't say whether the instructor watched him do those things cleanly five times or signed the form because it was the end of a long week. The certificate is a snapshot of a finish line. Proficiency is the whole run-up to it, and you can only prove that happened if someone wrote down how it went while it was going.


What “Telling the Proficiency Story” Means

That's really all "telling the proficiency story" means.

Where did this student start? The man who has been driving equipment his whole life and the one who'd never touched a clutch have different starting points.

How did each one come along over the weeks, the skills they wrestled with and the ones that finally clicked, the point where they stopped needing a prompt and just did it right?

And at the end, can you point to the moment he performed each required skill to standard, with a date and a name on it?

String those together, and you've got something an auditor can't argue with. Skip them, and you've got a piece of paper.

The instructor's judgment lived in their head and on a clipboard that got tossed at the end of the day so when the question finally came, there was nothing to hand over. They didn't fail at training. They failed at documentation.


Students walking in the training yard

The Problem With Pass/Fail

Underneath all of this, most schools have a grading problem they've never named. They grade proficiency the way you'd grade a road test: pass or fail, did it or didn't. The trouble with pass/fail is that it flattens everybody. Every student you certify ends up looking identical on paper, and identical is the one thing that's useless to the people now asking to see your records. They don't want to just know that they passed. They want to know how they got there.

You can't get there with a checkmark. You get there with a record that can show movement, a student who started shaky on his backing and, over several sessions, climbed to doing it right on his own. Which raises the fair question: what counts as good enough to call "proficient"? It feels like the rule leaves you guessing on the behind-the-wheel side, because it doesn't print a number the way it does for the theory test. But there's a defensible answer sitting in the same regulation, if you know which standard to borrow and how to apply it the same way every time. Get that part right and proficiency stops being one instructor's gut feeling and becomes something you can defend to anyone who walks in the door.


The Record Behind the Grade

The grade is only half of it, though. The other half is the record behind each grade, and that's more than a date. Every time a skill gets assessed, you want it tied to the student, the instructor, and the exact skill the way the regulation names it, with a signature, all answering one plain question: did this student show proficiency? Do that consistently and you're building an audit proof file in real time. The file built itself and the morning the notice audit arrives is just another Tuesday.

The same records support other stakeholders as well. The carrier looking at your graduate wants to know whether he's worth hiring. The insurer standing behind that carrier wants to know whether he's worth covering, and in this market they can't afford to gamble on a green driver they can't read. One documented proficiency story answers all three at once. The graduate who shows up with proof gets the job, and the school that sent him out with it gets the next class, because placement is the first thing every prospect asks about.



The Shift Schools Need to Make

None of this is more teaching. It's holding onto the call your instructors already make, in a form that's still there six months later when someone asks to see it. That's the whole shift, and it's smaller than it sounds. The schools that will stand up over time are the ones that can prove, skill by skill, how each student became ready to drive.

The Industry Is Moving In The Right Direction

September 23, 2026
Thoughts from Tim McLain National Academy Director, CDL PowerSuite Everyone Under One Roof For the first time in my career, we had FMCSA, AAMVA, state licensing agencies, publicly funded truck-driving schools, private CDL schools, and CVTA all under one roof. In more than 30 years in this industry, I've never seen every entity involved in training a driver gathered in the same room, talking openly, correcting misinformation, and aligning on the same mission. We Must Communicate Better You would think that more than four years after Entry-Level Driver Training came out, it would be one of the most clearly communicated parts of our industry. But last week proved otherwise. The biggest takeaway, beyond our shared commitment to safer drivers, was simple: we must communicate better. State licensing agencies were unaware of or unaligned with FMCSA requirements. FMCSA wasn't always responsive to those agencies. Auditors were inconsistent, and in some cases, simply wrong. Correcting Misinformation in Real Time Seeing these issues addressed directly, and watching misinformation get corrected in real time, was invaluable. One example: schools were told they were out of compliance because instructors didn't have a self-certification form in their files. Patrick Nemons clarified that this is not required for instructors, only for students. That's how much confusion still exists, and why every provider must be an expert in Part 380. If It's on Your TPR, You Must Be Able to Teach It Another major point: anything you list on your TPR must be something you can teach immediately. That means equipment, lesson plans, facilities, and instructor qualifications must all be in place. If not, you will be found out of compliance. And there is no gray area. You're either compliant or you're not. Even if you fix it on the spot, you will still be marked out of compliance and required to submit a Corrective Action Plan. And the consequences are real: schools must notify current and prospective students that their organization is under review. For some programs, that can be devastating. Why Real-Time Records Matter This is exactly why I sought out CDL PowerSuite while I was still running multiple campuses. You cannot rely on paper. Paper is a lagging measure. By the time you discover an issue, the student may already be gone. You need real-time information: equipment, instructor qualification files, student records, curriculum, evaluations, all accurate, all accessible, all the time. That's why I've been grateful to work with CDL PowerSuite and help schools achieve full transparency and compliance. A Gathering This Industry Needed Seeing FMCSA, PTDI, CVTA, NAPFTDS, and the SDLAs together was something this industry has needed for a long time. I'm grateful to PTDI for sponsoring the event, FMCSA for the grant that made it possible, and the leadership of CVTA and NAPFTDS for bringing their schools into the conversation. It was truly a once-in-a-lifetime gathering, but one I hope becomes a regular occurrence. Take Your TPR Certification Seriously On Thursday at the CVTA conference, we also received a legal briefing on federal activities related to the Training Provider Registry. One important takeaway: pay close attention when certifying your information in the TPR. Many in our industry move through that process too casually, without fully understanding the legal obligations they place on their organizations or how critical it is that every detail is correct. I won't dive deeper here, but it deserves your attention. Clearer Roles. Safer Roads. I could write a book about everything that was shared, corrected, and clarified. Everyone walked away with a clearer understanding of their role and, more importantly, how to communicate with one another. That clarity will benefit future drivers and make our roads safer. Have a Voice in Where This Industry Goes If you weren't there, you missed something special. If you're a school, you need to be part of CVTA or NAPFTDS, not just for the education, but to have a voice in how this industry moves forward. The value of sharing experiences, learning from peers, and gaining months' worth of insight in just a few days is immeasurable.

Reports from Around the Country: ELDT Audit Gaps

September 15, 2026
2026 has certainly been an eventful year for entry-level driver training (ELDT) and enforcement across the industry. We can all agree that we support the goal of making our highways safer, and in many ways, we applaud these efforts. However, when enforcement efforts cast a wide net, some organizations will inevitably be caught up in it. Unfortunately, that is sometimes the nature of enforcement. These audits provide an opportunity to examine how training providers can identify gaps in meeting ELDT requirements. At CDL Power Suite, we have received a significant number of questions and comments from training organizations. Our goal is to share some of the audit deficiencies we have seen throughout the industry. Student self-certifications One of the more surprising deficiencies—particularly during the first round of audits—involved student self-certifications under 49 CFR § 380.725(b)(1). It is remarkable how many organizations thoroughly addressed the curriculum, theory, and behind-the-wheel requirements but overlooked this provision. The required self-certification must be completed and maintained for every student. All applicants accepted for behind-the-wheel training must have this self-certification on file. Instructor qualification files The second most frequently reported deficiency involves instructor qualification files. Training organizations that use third-party examiners already understand the importance of keeping instructor qualification files current. This is critical. If an instructor’s file is not compliant for any period of time, the organization must be able to document that the instructor did not train students during that period. Instructor qualification files are essential, and we could spend an entire day discussing them. Most organizations understand what is required; the challenge is having a system that consistently monitors those files. Many items in an instructor qualification file require advance planning. If physical examinations, renewals, or other requirements are left until the last minute, an organization can quickly find itself in a difficult position. A reliable tracking and reminder system is essential. Training all six basic skills The third issue we have heard about most often involves organizations that train only for the modernized skills test. Given the amount of news and industry discussion surrounding ELDT, it is surprising that some organizations still do not understand that all six basic skills must be taught. We have even heard individuals say, “Our state told us we did not have to do that.” Unfortunately, the state will not be standing beside you during an audit, and that explanation will not satisfy an auditor. You must know what is happening on your training range. Many of us become so focused on keeping the operation moving that we never step back to see what is actually taking place. Be aware of team members who begin teaching only what is necessary to pass the test. We track first-time and overall pass rates, but we cannot allow the pursuit of better scores to cause us to abandon our principles or training standards. Every organization should have a consistent method for defining and documenting proficiency. Train instructors properly Before addressing any of these issues, we need to emphasize the importance of properly training instructors. Too often, organizations hire and train instructors in the middle of a crisis. That approach creates unnecessary risk. These audits are likely to continue. In my more than 30 years in the industry, I have not seen anything quite like them. They resemble an accreditation audit, a third-party audit, and a state board of education review occurring at the same time. Unlike many audits in the past, auditors already have access to information about your previous graduates through your Training Provider Registry (TPR) number. Your organization’s history is already reflected in the records they review. For that reason, it is vital to understand: - What is happening on your training range - How instructors are trained - How instructors’ grade and assess students - How your organization defines proficiency - What information is being entered into the TPR - How changes and updates are communicated to your team Too often, we overlook the seriousness of the information posted to the TPR. When you make a change or post information, slow down and explain to your team why accuracy matters and how seriously that information will be treated. These audits are not a one-time event. They are becoming a way of life for the industry.