Why We Built a 5-Point Rubric for CDL Training Proficiency

June 24, 2026

When we set out to solve the proficiency documentation problem in CDL training, the first question wasn't what to track. It was how to grade. Without a grading system that can show progression over time, you don't really have a proficiency story. You have a snapshot of one moment, and a snapshot doesn't hold up when someone asks you to explain a trainee's journey.

So we built a 1-to-5 rubric, and every level means something specific.

1 is "Unsafe." The student requires instructor intervention. They're having difficulty maintaining control, failing to hold lane position, grinding gears, or showing poor awareness of their surroundings. This isn't a student who's struggling to improve. This is a student who shouldn't be behind the wheel without active supervision.

2 is "Developing." This student is generally safe to put in traffic but needs consistent guidance and correction. They're meeting some criteria, making progress, but not operating consistently enough to be on their own yet.

3 is "Progressing On Track." It's one of the levels we thought most carefully about including. This student generally meets the criteria with occasional reminders, makes minor mistakes but corrects them with minimal instruction, and operates safely with minimal guidance. They're on a clear path to proficiency. A 3 in a student's record isn't a problem. It's documentation of a real stage in their development, and that's exactly what makes the overall story credible when someone asks to see it six months later.

4 is "Proficient." This student consistently meets performance criteria without reminders, recognizes and corrects minor mistakes on their own, operates smoothly and confidently, and requires little to no instructor input. When a student reaches a 4 across the required skills, they're ready to be certified.

5 is "Exceeding Expectation." We added this level deliberately because it reflects something real that happens in training. This student operates with full independent control and no instructor input at all. More than that, they anticipate traffic conditions and adjust before situations develop. They're not just meeting the standard. They're performing at a professional level. A 5 isn't required for certification, but it's documentable, and carriers putting new drivers on public roads from day one notice the difference.

We score each skill area separately: vehicle controls, shifting and transmission, communications and signaling, visual search, speed and space management, and safe driver behavior. A student can be strong in one area and still developing in another. Scoring each unit on its own makes those gaps visible before certification, not after.

Every skill area maps to the required curriculum units under 49 CFR Part 380, so when an instructor scores a student on categories such as upshifting, hazard perception, or railroad crossing procedure, that score directly corresponds to the regulatory requirement it satisfies. The loop between trained and proven gets closed.

The documentation bar for CDL training has moved permanently. What answers the question FMCSA is asking is a dated, skill-by-skill record showing where a student started, how they progressed, and where they finished, with an instructor's name and signature on every assessment. That's the proficiency story. The rubric is what makes it tellable.

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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.