Skill Performance Evaluation (SPE) Certificate

What the SPE program is and who actually needs it 

The Skill Performance Evaluation (SPE) program is the FMCSA pathway that allows otherwise qualified CMV drivers with a loss or impairment of an extremity (e.g., hand, arm, foot, leg) to operate interstate once they demonstrate safe driving ability, typically via specified on-road and off-road tasks, using appropriate prosthetic or adaptive equipment. 

By regulation, the SPE lives in 49 CFR §391.49. Applications can be joint (driver + employing motor carrier) or unilateral (driver alone). The application goes to the FMCSA Service Center that covers the driver’s licensing state (unilateral) or the carrier’s principal place of business (joint). 

The federal SPE is for interstate commerce. If the driver is strictly intrastate, the federal SPE doesn’t apply (your state may have a parallel process). The FMCSA will deny an SPE request that is intrastate-only. 

Skill Performance Evaluation requirements

Before you build the packet, confirm the driver is otherwise qualified and has a current DOT physical (MCSA-5875) and ME certificate (MCSA-5876). The SPE packet must also include a medical evaluation summary completed by a board-certified/qualified physiatrist or orthopedic surgeon(no substitutions). For upper-limb loss or impairment, the summary must address precision prehension and power grasp (with or without appropriate prosthesis/orthosis as specified). 

From experience managing DOT compliance end-to-end, we treat this medical summary like a linchpin: we brief the specialist with the job tasks and adaptive equipment ahead of time, so the evaluation lines up with the driver’s actual duties and equipment, this prevents back-and-forth and keeps your clock moving.

Your initial application must include (at a minimum): identification of applicants (driver and, if joint, carrier), description of operations (states, hours, commodities, operation type), description of the CMV and any vehicle modifications, a copy of the road test (or plan for a competent third-party test for unilateral applicants), the job application (391.21), any state-level limb-defect certificate, and MVRs for the last 3 years from every state where a license was held. FMCSA explicitly warns: they will not process incomplete applications. 

Operationally, we build these packets the same way we maintain a Driver Qualification File (DQF): every doc dated, legible, signed, and cross-checked. In practice, most delays we see come from missing signatures, outdated MVRs, or not checking the “Accompanied by an SPE” box on the ME forms, easy wins when you run a tight review before submission.

Step-by-step: first-time (initial) SPE application

1. Confirm scope (interstate): verify the driver truly operates or intends to operate across state lines (or carries interstate freight). If it’s intrastate only, stop and follow state rules instead; FMCSA will deny a federal SPE for intrastate-only operations. 
2. Assemble required medicals and specialist summary: include MCSA-5875/5876 and the medical evaluation summary (physiatrist or orthopedic surgeon) addressing function, stability, and prosthetic/orthotic needs for grasping or steering tasks.
3. Document the operation and the vehicle: spell out states, hours, commodities, CMV specs, any adaptive equipment, and attach photos where appropriate per §391.49(c). We front-load these details so the Service Center doesn’t need clarification.
4. Road test & employment docs: provide the road test certificate (carrier-administered for joint; qualified 3rd party allowed for unilateral) and the §391.21 application.
5. MVRs and housekeeping: pull 3-year MVRs from every licensing state. Validate that the ME forms have the SPE checkbox marked. FMCSA notes that they will not process incomplete or improperly assembled packets (e.g., double-sided pages, stapled, or folded). We audit this before submission and handle the filing so nothing gets rejected on a technicality.
6. Send to the correct Service Center: address the packet to the FMCSA Service Center covering the driver’s licensing state (unilateral) or the carrier’s principal place of business (joint). FMCSA lists Eastern, Midwestern, Southern, and Western centers; email is the preferred submission method.

When you take a full-service approach to DOT safety (our daily lane), you can fold the SPE milestone into your broader compliance program, so the driver’s qualification file, medicals, and SPE records march in lockstep.

Renewal: validity, timing, and what changes

Validity: The SPE is valid up to two years from the issue date. Renewals may be submitted 30 days before expiration. For renewals, FMCSA wants operational data since the last issue: miles driven under the SPE, any crashes (with details), updated ME forms, the specialist’s medical summary as applicable, and an MVR for the entire period the current certificate has been in effect. 

In practice, we calendar SPE renewals 60–45 days ahead to absorb clinic lead times and MVR turnaround. It’s the same “no surprises” discipline we apply to annual queries, MVR pulls, and med card expirations; simple calendaring avoids parked trucks.

Driving demonstration and equipment

Expect the SPE process to confirm that the driver can safely operate the CMV, including steering, shifting, braking, and emergency maneuvers, using any necessary prosthetic or orthotic device or vehicle modifications. The vehicle used must be representative of what the driver will operate. After an SPE is issued, the employing motor carrier must still road-test the driver with the trailer type(s) the carrier uses (or accept a comparable trailer road test). Job tasks (non-driving) are separately evaluated by the carrier. 

From the carrier side, we verify that the limitations and conditions on the SPE (vehicle type, required devices, etc.) are understood by operations and safety. Treat the SPE terms like any other qualification condition: visible, auditable, and enforced.

Interstate vs. intrastate: how to tell which lane you’re in

Federal SPEs are for interstate operation. If the driver, freight, or passengers cross state lines (or international borders), you are in interstate territory. If the entire trip starts and ends inside one state, that is intrastate; use state rules. This distinction matters: it decides whether you pursue the federal SPE or a state process. When in doubt, map your lanes and customers for the previous 90 days and the next 90 on the dispatch calendar. We do this routinely when onboarding new drivers.

Where to send and how to follow up (Service Centers)

FMCSA maintains four SPE Service Centers (Eastern, Midwestern, Southern, Western). Each lists an email address (preferred), phone, and fax, plus the states covered. Confirm you’re using the correct center and lean on email for cleaner tracking.

FAQs