MVR & CDLIS for fleets, without the SaaS contract

The volume math for a 50-driver fleet

A 50-driver carrier owes 50 annual §391.25 reviews a year, plus an MVR + CDLIS on every new hire. Pay-per-pull, that is $50 per annual MVR ($150 as an Annual Refresh with CDLIS and 12 months of Clearinghouse query management) and $75 per MVR + CDLIS at hire, so the bill tracks the pulls you actually run. A per-seat compliance platform bills for every driver whether or not a record is pulled; for larger fleets its workflow tooling can earn its keep on its own merits.

If you already use a TMS or compliance platform you like, that's great - pay-per-pull MVR vendors plug in alongside. If you don't, a $50/$75/$100/$150/$175 per-pull bill (matched to what each driver actually needs) is the cleanest way to keep the books straight.

§391.25 annual reviews on a calendar

The §391.25 annual MVR review is the single recurring item that fleets miss most often. The pattern is familiar: the safety director leaves, the hire-anniversary tracking spreadsheet stops getting maintained, and six months later the auditor finds twenty drivers whose annual reviews are 14 months stale. The fix is a calendar discipline - pick a cadence (anniversary-of-hire is cleanest, fleet-wide quarterly review is more practical) and run all the MVRs at once. A 50-driver fleet running quarterly batches of 12–13 MVR Basic pulls at $50 each is about $625 per quarter, four times a year - and the $150 Annual Refresh package adds CDLIS and 12 months of Clearinghouse query management (covering the §382.701(b) limited query) if drivers are CDL. It's a line item.

Each annual MVR pull pairs with a written one-paragraph review by a designated company official. The review note plus the MVR both go in the §391.51 DQ File and stay there for three years from the date of the review.

New-hire §391.23 packets

The §391.23 hire packet is where the MVR + CDLIS package earns its $10 premium over MVR Basic. CDLIS surfaces every state where the driver has held a CDL - including the surrendered learner's permit from twelve years ago and the suspended-for-DUI license they'd rather not mention. For a fleet running multi-state recruiting, the assumption that a driver has only ever held one CDL does not always hold. The $10 marginal cost catches those gaps pre-hire instead of mid-onboarding. For CDL hires you also have to clear the §382.701(a) Clearinghouse pre-employment query - the $175 DOT Pre-Employment package bundles MVR + CDLIS + PSP + 12 months of Clearinghouse query management (which covers that pre-employment query) in one transaction.

The §391.23 packet also requires a previous-employer inquiry covering the prior three years, with the responses kept in the separate §391.53 driver investigation history file for the duration of employment plus three years. The MVR + CDLIS is the document; the previous-employer paperwork is the workflow around it.

Audit posture

When the FMCSA auditor shows up, the documents they want pulled first are the §391.23 records on every driver hired in the last three years and the §391.25 annual reviews on the active roster. Both are MVR-anchored. A fleet that runs MVR + CDLIS through a single recordkeeping vendor - pay-per-pull or otherwise - produces those records in a single morning. A fleet that has been pulling MVRs ad hoc through the state DMV portal, with no central record of what got pulled when, spends two weeks reconstructing the file. The cost of clean recordkeeping isn't the per-pull fee; it's the audit week you didn't have to take.