Reports from Around the Country: ELDT Audit Gaps

September 15, 2026

Reports from Around the County: ELDT Audit Gaps

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.

Reports from Around the County: ELDT Audit Gaps


Know the requirements

As quality training organizations, we need to identify and repair the cracks in our armor. Improving our processes will benefit the public, our students, and every training organization that is working to do the right thing.


I may have rambled a bit, but I want to reiterate how many times I have heard someone say, “The state told us we only had to provide modernized training.” Every person involved in ELDT should be thoroughly familiar with the applicable requirements under
49 CFR Part 380, Subpart F.


We have also seen inconsistency among auditors. Their direction has not always been uniform, and organizations may receive different interpretations during different audits. Your best defense is to know the requirements and understand your own processes thoroughly.


It is much easier to clarify an issue while an audit is taking place than to reconstruct records and submit additional documentation afterward. Post-audit corrections often result in significant rework.


TPR score reporting

Another issue appearing on audit findings is the failure to submit scores to the TPR within 48 hours.


In the past, there was considerable misunderstanding about when theory or classroom results had to be submitted. Some organizations believed that theory scores did not need to be reported until the range or road portion was completed.


Some schools are still operating under that assumption. Organizations must understand and follow the applicable TPR reporting requirements. Accurate and timely reporting is an essential part of ELDT compliance.



We are setting a new standard for managing compliance

As we continue to hear about and gather information from audits, our intent is to share it with everyone so that we can all learn and improve. However, one thing is absolutely clear: We cannot continue operating as we have in the past.


Historically, many processes depended heavily on instructors completing timely assessments and returning paperwork at the conclusion of training. That approach makes it difficult to operate with confidence and consistency.


In my strong opinion, what is needed is a transparent, real-time system that allows you to see your entire operation at a glance. You should be able to monitor when evaluations are completed, how students are progressing, and whether all requirements have been met—without digging through files as thick as a phone book.


This is a new world. If you want to excel in it, we can help you get there.

August 17, 2026
Every certification your school submits to the Training Provider Registry rests on one thing: the instructor who signed off was qualified to do it. That makes instructor qualifications the single highest-stakes file in your building. When a student's record gets questioned, the school defends one certification. When an instructor's qualifications get questioned, every student that instructor ever signed off is in question at the same time. One gap, multiplied by hundreds of graduates. That is why instructor files deserve more attention than they usually get, and why "we know our people are qualified" is a sentence worth retiring. Knowing it and proving it are two different jobs. The second one is the one that counts. What qualified actually means The federal requirements come down to a few things. A behind-the-wheel instructor needs to hold a CDL of the same or higher class, with the endorsements needed for the vehicle they are teaching in, plus at least two years of experience driving that class of vehicle or two years of experience as an instructor. A clean licensing history matters too. An instructor whose CDL has been suspended, revoked, or cancelled in the recent past can be disqualified from teaching, even if their license looks valid today. Then the states add their own layer. Some require instructor licenses, background checks, or their own experience documentation on top of the federal floor. The federal rule is the minimum, and your state decides how much higher the bar sits. A school operating in more than one state can have different qualification requirements for instructors doing the same job. Qualified on paper, provable on demand Here is where schools get caught. The instructor genuinely is qualified. Twenty years behind the wheel, endorsements for everything, sharp as they come. But the file holds a photocopy of a CDL from three renewals ago and nothing else. When someone asks the school to prove the qualification, the proof is a phone call to the instructor asking them to bring their license in. A complete instructor file answers the question before anyone asks it. A current copy of the CDL with the right class and endorsements. Documentation of the experience that qualifies them, whether that is driving history or instructional history. The MVR on file and reviewed. State instructor credentials where they apply. Every requirement, matched to a document, sitting in one place. When an auditor asks, the answer takes minutes instead of a scramble. 
August 10, 2026
Every school knows the rule: the person who trains a student and the person who tests them have to be two different people. It is one of the oldest lines in third-party testing, and everyone in this industry can recite it. Knowing it happened is different from showing it happened Most schools keep the trainer and examiner separate every single time. The owner would swear to it, and they would be telling the truth. The problem is that swearing to it is all they can do. When the proof of separation lives in people's memory of who was working that day, the school has compliance that evaporates the moment memory fades or staff move on. To an auditor, a rule followed and a rule documented are two different things, and only one of them counts. The test of your documentation is simple. Pull a student file from eighteen months ago. Could a stranger look at that file and identify who trained the student and who examined them, on their own, in under a minute? If the answer requires someone to explain, the record is incomplete. The separation should be visible on the page itself. What the paper trail actually requires Two layers of documentation make the separation provable. The first is the training history. Every training event should name the instructor who delivered it. The person, specifically. A student's file should read like a roster of everyone who worked with them: which instructor ran their range sessions, which one sat with them on the road, on which dates. The complete list of who touched the student's training is the foundation, because proving the examiner was independent starts with a record of everyone who trained the student. The second is the testing record. The skills test should name the examiner just as clearly, tied to the date and the result. Put the two layers side by side and the separation proves itself. The examiner's name is absent from the training history, and the case is closed. Zero explanation, zero reconstruction, zero calls to the scheduler to vouch for who did what.