The Industry Is Moving In The Right Direction

September 23, 2026

Reports from Around the County: ELDT Audit Gaps

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.

October 27, 2026
As FMCSA increases oversight of the Training Provider Registry, CDL schools face greater pressure to maintain compliance, correct deficiencies, and demonstrate that their training meets federal standards. The Federal Motor Carrier Safety Administration (FMCSA) is taking an increasingly aggressive approach to enforcing Entry-Level Driver Training (ELDT) requirements. With more investigations, proposed removals, and regulatory oversight, CDL training providers need to understand what happens when FMCSA identifies a compliance issue. For training providers, even a single compliance finding can have significant consequences. FMCSA's strict enforcement approach means schools should no longer assume they will receive an informal warning or an opportunity to correct every issue before formal action is taken. A finding that identifies a material deficiency can lead to a Notice of Proposed Removal, placing a school's status on the Training Provider Registry (TPR) under public scrutiny. What Happens When FMCSA Finds a Compliance Issue? When FMCSA conducts an audit or investigation, it reviews whether a training provider meets the requirements outlined in 49 CFR Part 380. If investigators identify a deficiency, they may document it as a compliance finding. Depending on the nature of the finding, FMCSA can initiate the proposed removal process. Under 49 CFR 380.723 , FMCSA issues a formal Notice of Proposed Removal explaining the reasons for its decision and identifying any corrective actions necessary for the provider to remain registered. Being proposed for removal does not mean a school has been removed from the TPR. However, it does create immediate consequences. Once a Notice of Proposed Removal is issued: FMCSA publicly identifies the provider as being under review on the TPR. The training provider must notify all currently enrolled students and students scheduled for future training of the proposed removal. The provider must respond to FMCSA within 30 days of the notice. If corrective actions are required, the provider must complete them within the applicable deadline and provide supporting documentation. For a CDL school, this can create challenges beyond regulatory compliance. Students researching training programs may see that a school is under review. Current students may have questions about whether their training remains valid, and prospective students may reconsider enrolling. Even if a school ultimately resolves the finding and remains registered, the process can create uncertainty for students and additional administrative work for the provider. Corrective Actions: You Must Demonstrate Compliance Receiving a Notice of Proposed Removal is not necessarily the end of the road. FMCSA provides a process for training providers to respond to findings and address deficiencies. A provider may challenge the notice if it believes FMCSA relied on incorrect information, or it may indicate its intention to correct the identified deficiencies. For schools pursuing corrective action, simply stating that a problem has been fixed is not enough. FMCSA requires documentation demonstrating that the necessary corrective actions have been completed. This could involve updating training procedures, correcting curriculum deficiencies, documenting instructor qualifications, or demonstrating how the school has improved its assessment and recordkeeping practices. Under 49 CFR 380.723, providers generally have 60 days to complete required corrective actions, subject to the applicable regulatory timeline. FMCSA may request additional records or conduct further investigations to verify that the deficiencies have been addressed. If the provider successfully demonstrates compliance, it may remain listed on the TPR. If it fails to respond or complete the required corrective actions, removal can follow. In cases involving fraud, criminal behavior, willful disregard of the regulations, or certain public safety concerns, FMCSA also has authority to immediately remove a training provider without first following the ordinary proposed removal process. Why Documentation Is More Important Than Ever For CDL schools, the biggest takeaway is that providing quality training is only part of the responsibility. Schools must also be able to demonstrate that the training meets federal requirements. A school may have experienced instructors and a comprehensive training program, but incomplete records or inconsistent procedures can make it difficult to demonstrate compliance during an investigation. Training providers should regularly review how they document student progress, instructor qualifications, training assessments, behind-the-wheel proficiency, and curriculum completion. The goal should be to maintain records and procedures that can withstand regulatory scrutiny at any time, rather than attempting to reconstruct them after an investigation begins. Schools should also establish internal processes for identifying and correcting deficiencies before they become formal findings. The Future of CDL Training Is Built on Accountability FMCSA's continued enforcement efforts send a clear message to the CDL training industry: compliance is an ongoing responsibility, not a one-time registration requirement. The agency's efforts to remove noncompliant providers are intended to protect the integrity of the CDL training process and ensure that students receive the training required to operate commercial motor vehicles safely. For legitimate training providers, this makes proactive compliance more important than ever. The best time to identify and correct a compliance issue is before FMCSA identifies it for you. At CDL PowerSuite, we believe that strong documentation, consistent training procedures, and accurate records are essential to running a successful CDL training operation. As FMCSA continues strengthening oversight, the schools that prioritize these fundamentals will be better positioned to demonstrate compliance, maintain student confidence, and avoid unnecessary disruptions to their operations.
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