Ohio Law

FMCSA Audit Guidance

Below you will find guidance and insights from school transportation professionals who have recently gone through an FMCSA audit. We have also included two links to general FMCSA audit resources. Please note that these federal resources cover all commercial motor vehicle operations, including semi-tractor compliance, and therefore contain information that does not apply to school transportation operations. However, they may still be helpful for understanding the overall audit framework.

FMCSA Sample Communication

FMCSA is responsible for compliance with 49 CFR Part 380, Subpart F, Entry Level Driver Training Requirements, and Subpart G, Registry of Entry-Level Driver Training Providers. This audit will provide FMCSA with valuable input to ensure effective and efficient oversight of the ELDT/TPR program.

Please have all required documents, materials, and information readily available for review during the on-site audit within 48 hours of FMCSA’s issuance of this request, pursuant to 49 CFR 380.719(a)(4), (5), (6) and 380.725. Failure to permit FMCSA to audit a training provider’s operations or failure to make available the requested documentation within 48 hours of issuance of this request may result in the training provider’s removal from the TPR pursuant to 49 CFR 380.721(a)(1), (2) and 380.723. FMCSA is seeking to review the following:

Documentation of any and all State licenses, certifications, registrations, or authorizations permitting Warren County Educational Service Center to provide Entry-Level Driver Training in Ohio. Alternatively, provide documentary proof that you are exempt from Ohio’s State licensure, certification, registration, and/or authorization requirements. 49 CFR 380.719(b)(5).

The lesson plans for theory [and Behind-the-Wheel (BTW) (range and public road)] training curricula, as applicable. For Theory include resources used, such as lecture outlines, demonstrations, audio-visual presentations, computer-based instruction, driving simulation devices, online training, etc. [For Behind the Wheel, how the provider meets the road and range requirements for the entry-level driver to demonstrate that the driver is in control of the vehicle in applicable settings.] 49 CFR 380.725(b)(4).

Documentation related to the vehicles used for BTW training (e.g., VINs, vehicle registration, current inspection reports, if applicable) and which skills tests, knowledge tests, or lesson plans the vehicles are used to test. 49 CFR 380.711, 380.725(b)(4).

Documentation related to instructor qualification documentation indicating driving and/or training experience, as applicable, for each instructor and copies of commercial driver’s licenses and applicable endorsements held by theory instructors and/or BTW instructors, as applicable. 49 CFR 380.725(b)(3).

Documentation related to records of individual entry-level driver training assessments. 49 CFR 380.725(b)(5).

Copies of self-certifications by all accepted applicants for behind-the-wheel (BTW) training attesting that they will comply with U.S. Department of Transportation regulations in parts 40, 382, 383, and 391, as well as State and/or local laws, related to alcohol and controlled substances testing, age, medical certification, licensing, and driver records. 49 CFR 380.725(b)(1).
List all DRIVERS’ NAMEs 49 CFR 380.725(b)(2).

Copies of the driver-trainees’ commercial learner’s permits or commercial driver’s licenses, as applicable.
List all DRIVERS’ NAMEs 49 CFR 380.725(b)(2).