Explore the sections in this guide
The short answer
Section 391.25 generally requires the carrier to obtain driving records and review each covered driver’s record at least every 12 months. The inquiry covers the licensing authorities where the driver held a CMV license or permit during the preceding 12 months. The carrier evaluates continued qualification, considering the accident record and violations, with particular weight given to serious conduct. Keep the MVR and a review note identifying the reviewer and review date in the qualification file. Check the section’s applicability and exceptions.
Do not confuse ordering with reviewing
A vendor receipt can show that an order was placed. A returned MVR shows the record supplied. Neither, by itself, explains who evaluated that record and when. Use separate fields for the requested date, returned date, completed review date, reviewer, and unresolved issue. This makes an overdue order visible without disguising it as a finished review.
Compare these three records
Start with the driver roster, the returned MVR, and the review note. Match the person and licensing jurisdiction before reading the entries. Then compare the dates. A roster marked complete may have been updated when the order was placed; a note may refer to last year’s record. Record the actual discrepancy instead of checking the box because a document is present.
Example: the subscription says complete
A carrier uses an outside record service. The dashboard marks an MVR delivered, but the file contains no note identifying a carrier review. Locate the delivered record and ask the designated reviewer to evaluate it. Document the work on the date it occurs. If a prior review really occurred, find the original evidence; do not create an earlier date to match the dashboard.
Build the calendar around people
An equipment list will not tell you which drivers need review. Assign responsibility for roster changes, new licensing jurisdictions, incoming records, and unresolved entries. Keep a backup reviewer so an absence does not stall the process. Use reminders to schedule work, then close the reminder only when the record and review evidence have been checked.
When a record raises a question
Confirm the entry belongs to the driver and obtain the details needed for the qualification decision. Preserve the record received. A disagreement with an entry and a carrier’s qualification decision are separate issues; do not simply delete an unfavorable record from the file. Escalate uncertain qualification questions to the person responsible before relying on a routine completion flag.
Questions fleet offices ask
Does continuous monitoring replace the annual process? Do not assume it does; compare the service’s actual output with the applicable rule. Is a current CDL enough? It addresses licensing, not completion of the annual review. Can PassPro organize the review? We can compare the roster, files, and review process within the agreed scope and identify missing evidence; the carrier retains responsibility for qualification decisions.
Use the matching PassPro form
Retain the review evidence
Keep the annual MVR and the dated review note in the qualification file. Under §391.51, these annual records may be removed three years after execution. The file’s overall employment-plus-three-years rule does not make every component subject to the same removal date. An initial hiring inquiry and an annual review serve different requirements.
Obtaining the MVR and reviewing it are separate duties
Section 391.25 calls for the inquiry and review at least once every twelve months. The inquiry covers the preceding twelve months and the licensing authorities where the driver held a CMV license or permit during that period. The review addresses minimum safe-driving qualifications and disqualification, including the accident record and relevant violations. The qualification file needs the MVR and a note naming the reviewer and the review date.
Example: the vendor delivered the record, but nobody reviewed it
A provider sends an MVR on September 12. The office uploads it and closes the task. If the carrier has not performed and documented the required review, delivery alone has not completed the process. Identify the reviewer, record the actual review date, and address anything affecting qualification. As an internal control, track inquiry and review completion separately so the next person can see what remains open.
Official source
Applicability, exceptions, and state requirements can differ. Check the linked rule for your operation. Examples describe fictional situations.
