DQF Completeness Checker
Walk every item required by 49 CFR §391.51(b) and its companion rules. For each, mark whether you have it on file. The tool will compute a completeness score and list the gaps you need to close.
Completeness score
Mark the first item and the score fills in here — gaps listed first, each with its CFR citation.
Item 1 · §391.21
Driver's application for employment
Signed application with the §391.21(b) items: 3-year residence, accident, violation, and employer history; every unexpired CMV license or permit; and, for CDL applicants, CMV employers for the 7 years before that (§391.21(b)(11)).
Retention: Duration of employment + 3 years
Item 2 · §391.23(a)(2)
Inquiry to previous employers
Documented safety-performance-history inquiry to each DOT-regulated employer of the driver in the preceding 3 years (§391.23(d)–(e)), with the responses or documented good-faith attempts. Kept in the §391.53 investigation file — auditors ask for it alongside the DQF.
Retention: Duration of employment + 3 years
Item 3 · §391.23(a)(1)
Initial MVR from each licensing state
MVR from each driver's licensing authority where the driver held or holds a motor vehicle operator's license or permit in the preceding 3 years, requested within 30 days of hire (§391.23(a)(1)).
Retention: Duration of employment + 3 years
Item 4 · §391.25(a)
Annual MVR (most recent)
MVR pulled at least once every 12 months, covering at least the preceding 12 months, from each licensing authority where the driver held a CMV operator's license or permit during that period — prior licensing authorities included, not just the current one (§391.25(a)).
Retention: 3 years per inquiry
Item 5 · §391.25(b) / (c)(2)
Note of annual review of driving record
A note naming who reviewed the annual MVR and the date of the review (§391.25(c)(2)); the review itself decides whether the driver still meets minimum safe-driving requirements or is disqualified under §391.15 (§391.25(b)).
Retention: 3 years per review
Item 6 · §391.31 / §391.33
Road test certificate (or CDL in lieu of)
Either the road test certificate (§391.31(e)), or a legible copy of the license or certificate the carrier accepted as equivalent — a valid CDL for the vehicle type (double/triple-trailer and tank endorsements excluded) or a road test certificate issued within the preceding 3 years (§391.33(a)–(b)).
Retention: Duration of employment + 3 years
Item 7 · §391.51(b)(6)
Current medical examiner's certificate
The medical examiner's certificate or a legible copy, unexpired (§391.51(b)(6)(i)). For CDL holders the record is different: the CDLIS motor vehicle record from the current licensing State showing medical certification status, placed in the file (§391.51(b)(6)(ii)). Verifying the examiner on the National Registry is a separate item (item 10) and does not substitute for either.
Retention: May be removed 3 years after the certificate's date (§391.51(d)(3))
Item 8 · §391.49
Skill performance evaluation certificate (if applicable)
Required only for drivers operating under an SPE for a physical impairment. The driver supplies each employing carrier a copy (§391.49(f)); the carrier keeps it in the driver qualification file (§391.49(j)(1)).
Retention: Duration of employment + 3 years — §391.49(j)(1) requires the carrier to keep a copy for 3 years after the driver's employment ends. §391.51(d)(4) only lets the copy come out of the qualification file 3 years after execution; it does not shorten the carrier's retention.
Item 9 · §391.51(b)(6)(iii) / (b)(7)
Medical variance documentation (if applicable)
Required only when the driver's medical certification rests on an FMCSA medical variance — file a copy of the variance documentation with the certificate (§391.51(b)(6)(iii)). A Part 381 medical exemption document is filed under §391.51(b)(7); the SPE certificate is item 8.
Retention: 3 years from execution
Item 10 · §391.51(b)(8) / §391.23(m)(1)
NRCME verification note (non-CDL drivers)
A note verifying the medical examiner was listed on the National Registry of Certified Medical Examiners as of the certificate's issue date. Required for non-CDL drivers since May 21, 2014 (§391.23(m)(1), §391.51(b)(8)(i)). For CDL drivers the note was required only through June 22, 2025 (§391.51(b)(8)(ii)) — their CDLIS MVR carries medical certification status instead.
Retention: 3 years from execution
Item 11 · §382.301
Pre-employment drug test result
Verified negative drug test result before the driver performs any safety-sensitive function.
Retention: 1 year minimum for a negative or canceled result (§382.401(b)(3)); 5 years for a verified positive or a refusal (§382.401(b)(1))
Item 12 · §391.23(e) / §382.413
Previous-employer drug & alcohol testing inquiry
Documented inquiry into the driver's alcohol and controlled-substances history with prior DOT-regulated employers (§391.23(e)); for FMCSA-regulated prior employers this is satisfied through the Clearinghouse query since January 6, 2023 (§382.413(b)). Kept in the §391.53 investigation file.
Retention: Duration of employment + 3 years
Item 13 · §391.15
Disqualification documentation (if applicable)
Records of any disqualification under §391.15, the basis, and any corrective action. Not an enumerated §391.51(b) item, and §391.15 itself does not require a standalone document — recommended practice, so the file explains the gap once a disqualification has occurred.
Retention: Duration of employment + 3 years
Not on this list · §391.27
The annual list of violations is no longer required
Older DQF templates still ask for a driver-furnished annual list of violations under §391.27. That requirement was rescinded on May 9, 2022 — the annual MVR and review (items 4 and 5 above) cover it. If a template tells you to collect one, the template is out of date.
Gap report
Close these items before your next audit.
- Driver's application for employment (§391.21)
- Inquiry to previous employers (§391.23(a)(2))
- Initial MVR from each licensing state (§391.23(a)(1))
- Annual MVR (most recent) (§391.25(a))
- Note of annual review of driving record (§391.25(b) / (c)(2))
- Road test certificate (or CDL in lieu of) (§391.31 / §391.33)
- Current medical examiner's certificate (§391.51(b)(6))
- Skill performance evaluation certificate (if applicable) (§391.49)
- Medical variance documentation (if applicable) (§391.51(b)(6)(iii) / (b)(7))
- NRCME verification note (non-CDL drivers) (§391.51(b)(8) / §391.23(m)(1))
- Pre-employment drug test result (§382.301)
- Previous-employer drug & alcohol testing inquiry (§391.23(e) / §382.413)
- Disqualification documentation (if applicable) (§391.15)
How to use this checker
For each item, mark Have if the document is on file, Partial if some but not all of the required content is present, and Missing if you don't have it. Items marked Not applicable are excluded from the score.
The §391.51 list applies to every CMV driver — including the owner-operator who is also the only driver. There is no single-driver exemption.
What the checker doesn't do
This is a self-assessment, not a legal review. It cannot verify that your documents are correctly filled out, current, or signed by qualified people. For your specific situation, consult counsel or a qualified compliance professional.
Roadworthy HQ shows every item on this list as present or missing for each driver, and enforces each document's retention period. Start a 14-day free trial to build your DQF in 15 minutes.