The opening-day transportation roster may look complete. Every route can have a driver, every required bus can have a monitor or attendant, and every contractor can report that staffing is ready. Yet one expired physical performance test can make an employee legally unqualified to transport students.

That is the operational warning inside revised guidance posted by the New York State Education Department’s Pupil Transportation Unit. NYSED announced that its updated Physical Performance Test Guidelines apply to all school bus drivers, monitors and attendants.

The update does not create a new test or replace the underlying regulations. It refreshes the instructions districts, BOCES and transportation contractors use to administer and document a longstanding state qualification requirement. Its timing, as school systems finalize routes and personnel assignments for 2026-27, makes the guidance more than a routine administrative revision.

Under Section 156.3 of the Commissioner’s regulations, covered drivers must pass an approved physical performance test before transporting students and at least once every two years. The interval between tests cannot exceed 25 months.

A driver also must be tested after being unavailable for scheduled work duties for at least 60 consecutive days. The same testing schedule applies to school bus monitors and attendants, including the requirement triggered by an extended period away from service.

That provision warrants special attention during the late summer rush to fill routes. A returning employee may still hold the appropriate license, appear on a contractor’s personnel roster and have years of experience behind the wheel. If the employee has been unavailable for 60 consecutive days, however, the return-to-service process must include a new physical performance test.

The test is separate from a driver’s annual medical examination. A medical examination determines whether the driver has the physical and mental ability to operate a school transportation vehicle safely. The physical performance test measures whether the person can perform specific functions that may be required during daily operation or an emergency.

For drivers, those functions include climbing and descending bus steps, reacting quickly from the throttle to the brake, repeatedly depressing the brake or clutch pedals, operating the service door and hand controls, exiting through a rear emergency door and demonstrating the ability to evacuate passengers during an emergency.

Monitors and attendants are tested on duties that include climbing the bus steps, manually opening and closing the service door, exiting through the rear emergency door and demonstrating the ability to evacuate people from a bus. Those functions are especially consequential for attendants assigned to students whose individualized education programs (IEP) require specialized transportation support.

Both tests must be administered by a currently certified School Bus Driver Instructor. Completed test forms are submitted electronically to NYSED’s Pupil Transportation Unit.

A driver who fails any portion is unqualified to operate a school transportation vehicle with passengers until a re-examination is passed. A monitor or attendant who fails is likewise unqualified to perform that position’s duties. State regulations permit a re-examination, but no more than one may be administered to the employee on the same day.

The compliance responsibility does not end when a district contracts out transportation. State regulations cover school buses owned, leased or contracted for by school districts and BOCES. A private carrier may employ the personnel and maintain the files, but the district remains responsible for ensuring that the people transporting its students satisfy state requirements.

Transportation compliance can be compromised when it’s primarily viewed as a contract-management task. While a contractor’s commitment to provide a sufficient number of qualified employees is crucial, it’s not a substitute for tangible evidence linked to the names on the active roster.

District officials should request a certification covering every driver, monitor and attendant expected to work on district routes. The review should identify the employee, position, most recent test date, expiration window and any return-to-service test required after 60 consecutive days of unavailability.

The first review should focus on the places where roster problems are most likely to hide: new hires who have not transported students before, substitutes added to cover vacancies, employees returning from medical or other extended leave, workers transferred from another contract and personnel whose two-year testing window expires early in the school year.

Substitute status does not create an exemption. The regulation applies before a covered employee transports students, regardless of whether that person works a permanent route or fills in when the regular employee is absent. A substitute roster should therefore be tested against the same documentation standard as the daily assignment sheet.

Districts should also avoid using the phrase “current through the school year” without checking the underlying date. The regulation requires testing at least once every two years and prohibits an interval longer than 25 months. A test that is valid on the first day of school may still expire while classes are in session.

A stronger control is a rolling expiration report that identifies tests coming due during the next 30, 60 and 90 days. That approach gives transportation offices and contractors time to schedule testing before an employee becomes unavailable for service.

The documentation should connect to NYSED’s broader transportation reporting structure. Districts now report active driver, monitor and attendant rosters through the Transportation Compliance Form twice each year, with reporting dates of November 15 and May 15. A district that reconciles its records only when the form is due risks discovering a qualification problem after the employee has already been assigned to students.

The revised guidance arrives at the point when personnel files must become operating controls. Before the first bus leaves its yard, districts should be able to match every name on every route to a current physical performance test, then preserve that verification for the next roster review.

Opening-day transportation readiness is usually measured by whether buses arrive, routes are covered and families receive accurate pickup times. NYSED’s update adds a less visible question that districts should answer before students board: Is every adult assigned to this bus physically qualified under state requirements to do the job?