Documenting English Language Proficiency

September 30, 2026

A Conversation Tells You More Than a Checkbox

When an instructor is unsure whether a student can understand and communicate sufficiently in English, a documented conversation can help the school identify what the student can do and where additional support is needed.

While Part 380 governs ELDT training providers and their curriculum requirements, Part 391 establishes driver qualification standards, including English language proficiency. Incorporating ELP observations into your curriculum and addressing identified concerns before public-road training can help ensure that students are not put on the road before they can understand and communicate sufficiently in English.

CDL PowerSuite recommends incorporating practical English language proficiency (ELP) questions into your curriculum and documenting the instructor's observations. These conversations can take place during enrollment, classroom instruction, or pre-trip practice, with follow-up assessments as the student progresses.

Understand the Standard

Under 49 CFR § 391.11(b)(2), drivers subject to the rule must have sufficient English ability to converse with the public, understand highway traffic signs and signals, respond to official inquiries, and make entries on reports and records.

FMCSA's guidance for motor carriers recommends an English-language interview covering trips, duty time, license information, shipping papers, and vehicle equipment. Schools can adapt these topics to situations students encounter during training. That adaptation is our recommendation. The guidance is directed to motor carriers and does not prescribe the school questions below.

Separately, 49 CFR § 380.707(a) requires accepted BTW applicants to certify that they will comply with specified DOT regulations, including Part 391, in the areas listed in that section. Our recommended instructor observation record supplements the school's process. It does not replace the required applicant certification.

Start With a Conversation

Explain the purpose to the student: the school wants to understand their ability to communicate in situations they may encounter as a commercial driver.

Ask open-ended questions and let the student respond in their own words. Follow up naturally to see whether they understand the question and can explain their answer beyond a memorized phrase.

For the spoken-English assessment, have the student respond without an interpreter, translation app, or prepared answer script. FMCSA recommends avoiding these aids during the motor carrier interview because they can mask difficulties communicating independently.

Use the same observation criteria consistently. Focus on understanding and clear communication rather than accent or perfect grammar. Also distinguish a language difficulty from a topic the student has not yet learned.

Five Conversations to Incorporate Into Your Curriculum

1. Getting Here and Describing a Route

Related FMCSA interview topic: The origin and destination of a trip.

Suggested questions:

How did you get to the school today? Take me through the route.
Tell me about the longest drive you have ever made. Where did you start and where did you end up?
If I told you to go from here to the nearest truck stop, how would you explain the way to me?

What to document: Whether the student understood the questions, identified starting and ending points, and explained directions in a way the instructor could follow.

2. The Commercial Learner's Permit

Related FMCSA interview topic: Information contained in the driver's license.

Suggested questions:

What class of license are you working toward, and what will that let you drive?
What endorsements do you want, and why?
Read me the restrictions printed on your permit and tell me what they mean.
When does your permit expire?

What to document: Whether the student could locate, read, and explain relevant information on their permit. Note separately whether unfamiliar licensing terminology affected the response.

3. Hours, Schedule, and the Daily Log

Related FMCSA interview topic: Time on duty and the record of duty status.

Suggested questions:

Walk me through your training schedule this week.
Using the hours-of-service rules we covered for this operation, explain the driving limit and required break.
Look at this sample log page. What was this driver doing at 9 a.m.?
What is an ELD, and what does it record?

What to document: Whether the student could describe times and activities, interpret the sample log, and explain the material in their own words. Use the schedule question early in training and the technical questions after those subjects have been taught.

4. Talking to an Officer at a Roadside Inspection

Related ELP skill: Understanding and responding to official inquiries.

Suggested questions:

An officer approaches your window at a scale house and asks for your license. What do you do?
The officer asks what you are hauling and where you are headed. Answer out loud as you would during the inspection.
The officer tells you to shut off the engine and step down from the cab. Explain what you would do.
The officer says you are being placed out of service. What does that mean, and what would you do next?

What to document: Whether the student understood the requests and instructions, responded appropriately, and could handle a follow-up question.

5. The Pre-Trip Inspection in the Student's Own Words

Related FMCSA interview topic: Vehicle equipment subject to inspection.

Suggested questions:

Name five things you check before you drive, and tell me what you are looking for on each.
Point at the tires and describe what makes one unsafe.
What would you do if you found a light out during your inspection?
Where is the fire extinguisher, and when would you use it?

What to document: Whether the student could identify components, explain their observations, and describe an appropriate response to a problem.

The topic connections above draw on FMCSA's motor carrier interview guidance and the official-inquiry element of § 391.11(b)(2). The questions are school assessment examples developed by CDL PowerSuite.

Include Signs, Shipping Papers, and Written Records

These five conversations are a useful starting point, but spoken answers alone do not address every part of the ELP standard.

Add activities in which students interpret highway signs and dynamic message signs, locate information on sample shipping papers, and make a short entry on a sample inspection report or other record.

FMCSA's motor carrier guidance allows a highway-sign explanation in any language the evaluator understands. Document how the activity was conducted, and keep sign comprehension separate from the English-speaking assessment.

Document What the Instructor Observed

A useful record should include:

Student name, date, and instructor name
Questions asked and materials used
A brief summary of the student's responses
Specific observations about comprehension and communication
Any prompting, repetition, or assistance provided
Knowledge gaps recorded separately from language concerns
Follow-up instruction, reassessment date, and outcome
Instructor sign-off

For example:

Student independently described the route to school and explained the permit expiration date. During the mock roadside conversation, the student did not understand the instruction to shut off the engine after it was repeated. Additional instruction and reassessment are scheduled before public-road training.

This gives the school a more useful record than a checkbox stating "English proficient."

Use the Findings to Guide the Next Step

If a conversation reveals uncertainty, document the concern and arrange additional instruction and reassessment. Where concerns affect the student's ability to understand safety directions or satisfy applicable driver qualifications, our recommendation is to resolve them before public-road BTW training.

The purpose is to support student readiness and give instructors a consistent way to record what they observe. A school assessment documents performance at that time. It does not guarantee the outcome of a later roadside evaluation.

Practical Conversations. Specific Observations. Clear Next Steps.

Begin with practical conversations, record specific observations, and use the results to guide training and follow-up.

References

49 CFR § 391.11, General qualifications of drivers
FMCSA: Assessing a CMV driver's English language proficiency during driver qualification
49 CFR § 380.707, Entry-level training provider

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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.