A trucking company in San Antonio got an FMCSA audit notice on a Thursday morning. They had 48 hours to pull records for 14 drivers.
Two DQFs were missing the annual MVR review. One medical card had expired 60 days prior and nobody had noticed. They passed with a Conditional rating — but it took three people an entire day of scrambling to get there.
Could you say, without looking it up, which type of audit your fleet would even get, and exactly what the investigator is going to check?
No idea, right?
And that’s exactly the problem.
It’s not that the process is a mystery on purpose. It’s that nobody explains it to you until you’re already inside one, the clock running, the investigator waiting.
A medical card that expired 60 days ago and nobody noticed… and it’s the first thing the investigator finds, in the very first file he opens.
An audit everyone assumed was “routine”… that turns into a full Compliance Review because one BASIC score came back bad in the SMS system.
A file that looks fine on the surface… until they check the last 12 months of MVR and it’s not there.
I don’t know which type of audit you’d get, or when. But I know most carriers that fail don’t fail because of bad intent — they fail because nobody checked what the investigator was actually going to check.
The 3 Types of FMCSA Audits
New Entrant Safety Audit. For carriers within their first 18 months of operation. Required within the first 12 months under 49 CFR Part 385.319. It checks whether the carrier understands and follows the basic rules — not whether it’s perfect. Most new entrant audits result in educational intervention rather than enforcement, unless there are serious violations. Failing results in a Notice to Cease Operations.
Compliance Review (CR). For carriers flagged as high-risk by the Safety Measurement System (SMS), carriers following a crash, or carriers selected from driver or shipper complaints. A full review of all BASICs: driver fitness, hours of service, vehicle maintenance, controlled substances/alcohol, hazardous materials, and crash indicators. Ends in a Satisfactory, Conditional, or Unsatisfactory rating. An Unsatisfactory rating requires corrective action within 45 days (property carriers) or 60 days (passenger carriers), or the carrier faces a Notice to Cease Operations under 49 CFR Part 385.13.
Focused Investigation. Narrower than a full CR — it targets one or two specific BASICs flagged in SMS data, such as driver fitness or hours of service. Can escalate to a full CR if the investigator finds violations outside the initial scope.
What Investigators Actually Review
Driver Qualification Files
The first area investigated and the one with the most violations at small carriers. The investigator pulls a sample (10% of drivers or a minimum of 3–5 files) and checks for a valid CDL for the vehicle class, current medical certificate, MVR from the past 12 months, employment application, road test, drug test, and Clearinghouse queries. Common violations: MVR not obtained annually, expired medical certificates still on file, no Clearinghouse query documentation, or an incomplete employment application. A pattern of incomplete DQFs across sampled files results in a Conditional or Unsatisfactory rating for the Driver Fitness BASIC.
Hours of Service Records
They request 6 months of ELD data or paper logbooks. For ELD-regulated carriers, they verify FMCSA registration and full retention with no tampering. For carriers exempt from ELD, they check that paper logs are complete and show no pattern of falsified records.
Vehicle Inspection and Maintenance
Annual inspection records (retained 14 months), DVIRs (retained 3 months), and evidence that defects reported in DVIRs were actually repaired. Common violations: annual inspection not done, or done by an uncertified inspector.
Drug and Alcohol Testing Program
For carriers with 2+ drivers: proof of enrollment in a DOT-compliant consortium, random testing (minimum 50% drug, 10% alcohol annually), and Clearinghouse records, including return-to-duty documentation for any driver who tested positive.
With this list of what investigators actually look at, the logical next step is auditing yourself before the notice arrives.
GoExpirely does one simple thing: it watches every expiration date for every vehicle and driver, and warns you before it's a problem. No spreadsheet to update, no sticky note to lose.
Try it freeKnowing what gets reviewed is half the job — the other half is having a system that keeps those records complete without anyone chasing them down manually every month.
Written by Julio Alvarez — builder of GoExpirely and other software tools for operators and small businesses in the US.