In New York’s Article 19-A program, compliance starts long before a driver gets behind the wheel. One of the most overlooked responsibilities carriers face is ensuring that DMV's form 874 or FMCSA's form 5875 (Medical Examination Reports) are fully completed, every required field, every signature, every date.
Unfortunately, most carriers don’t understand that even though the examiner performs the exam, the carrier is responsible for making sure the form is filled out correctly.
This single detail has led to compliance findings, citations, and preventable delays during audits. Let’s break down why this matters and how carriers can protect themselves.
Doctors and examiners are trained in medical standards, but they aren’t responsible for your 19-A compliance. If a required field is left blank, incomplete, or incorrectly marked, the State does not hold the examiner accountable, they hold the carrier accountable.
That means the carrier must review each Medical Report after the exam to confirm the following:
One missed box can turn a medically qualified driver into a compliance issue.
1. A Missing Field Can Void a Qualification
If the examiner fails to check a required box, the State may treat the form as incomplete, meaning the driver is not medically certified under Article 19-A.
2. It Protects the Carrier During an Audit
State auditors review these forms closely, and incomplete medical reports are one of the most common findings. Carriers who review the Medical Report before filing dramatically reduce violations.
3. It Prevents Delays in the Certification Process
When forms come back incomplete, carriers must chase the examiner for corrections, causing downtime and operational delays for the driver.
4. It Ensures Clear Documentation of the Driver’s Fitness
A properly completed Medical Report helps prove that the carrier acted responsibly and followed hiring and annual review requirements.
To stay compliant and protect your operation, build this simple workflow:
1. Create an internal checklist for Form 874
Include every required field, signature, and medical determination.
2. Train whoever reviews medical files
Whether it’s HR, a safety manager, or a19-A examiner, they must know what complete documentation looks like.
3. Verify forms before filing
Do not assume the doctor completed everything. Review each form before placing it in the driver’s qualification file.
4. Establish a correction process
If something is missing, immediately request an updated form, do not rely on verbal confirmation.
Even though the medical examiner performs the evaluation, carriers are ultimately responsible for ensuring the Medical Report is accurate and complete.
A strong internal review process protects your operation, avoids audit findings, and ensures every driver is properly certified.
If you want help creating compliance checklists, training tools, or full Article 19-A program support, We can help you build a system that eliminates errors and reduces audit risk. Reach out today and streamline your certification process.
