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.
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.
