Happy New Year. 2014 will mark the year that certain changes will take effect in the Department of Transportation (DOT) physical, also known for short as the DOT physical or the Commercial Driver License (CDL) physical or CDL physical. The DOT physical requires commercial drivers to undergo a medical evaluation and physical examination to determine their physical and mental fitness to operate a commercial vehicle (CMV) at least every 2 years. Two important dates to remember:
1. January 30, 2014: This is the deadline for commercial drivers to provide their State Driver License Agency (SDLA) information regarding the type of CMV operation they drive in or expect to drive in with their CDL (Four types of transportation exist: Non-Excepted Interstate, Non-Excepted Intrastate, Excepted Interstate, and Excepted Intrastate)*. By requiring drivers to self certify it will help identify CDL drivers who drive in Non-Excepted transportation and require them to submit a valid copy of their medical examiner’s certificate to their SDLA. So, commercial drivers that self certify as Non-Excepted Interstate or Non-Excepted intrastate will need to submit a current medical examiner’s certificate to their respective SDLA. This is an attempt by the Federal Motor Carrier Safety Administration (FMCSA) to integrate the CDL with the medical examiner’s certificate. The FMCSA published a Notice of Proposed Rule Making (NPRM) on May 10, 2013. In New York State, as in many other states beginning around the summer of 2013 drivers have been receiving by mail a self certification form based on the order of their Client ID number (9 digit Driver License number) from around late July 2013 to the end of October. If you’ve been putting it off remember to self certify. Failure to do so can cause you to lose your CDL.
2. May 21, 2014: Compliance with the National Registry of Certified Medical Examiners (NRCME) is required.** This is a new FMCSA program that requires all medical examiners who wish to perform, or continue to perform DOT physical examinations to be trained and to certify in the FMCSA qualification standards for commercial drivers. Previously, a driver could see his personal physician for these exams. Now medical examiners who wish to perform these exams will have to undergo training with an accredited training organization, prior to taking and passing the actual NRCME certification exam administered by various testing organizations. Although this does set a common standard by which all medical examiners are trained and certified that did not exist prior to this in the trucking industry, it also allows the goal of integrating the CDL and the medical examiner’s certificate described above to be possible and likely other goals of integration or centralization in the FMCSA medical programs. By requiring medical examiners performing DOT physicals to become certified, all medical examiners will now have a National Registry Number, and once certified will be required to log in and enter all completed DOT medical exam results of commercial drivers into the NRCME database by the end of the business day (this is required from all medical examiners by the compliance date May 21, 2014). The FMCSA will then forward the medical certification status of the driver to the Commercial Driver Licensing Information System (CDLIS) where millions of driver records are stored. Once this integration program is fully implemented in about 3 years, medical examiners will no longer need to issue the medical examiner’s certificate to drivers with a CDL, providing an efficient system exists whereby driver DOT physical exam result are transmitted to the NRCME who will then relay to or have it captured by the CDLIS. In the mean time, until this happens, CDL drivers should submit their Medical Examiner’s certificate to their SDLA and employer and will need to carry their medical examiner’s certificate for 15 days following a new DOT physical exam to allow the CDLIS to update their information.
Discussion:
Well, what do you think about all of these changes? Unfortunately, it’s likely that doctors who really don’t do too many of these exams may not bother to go to the trouble to get certified. The time and expense of taking a training course, studying the material and then sitting down for an exam might deter some practitioners, already swamped in their busy practice. This may become more of an issue in rural areas where healthcare providers are usually in shortage anyway and where close to half of commercial drivers reside. Since it has been estimated that 80 percent of highway roads cut across rural areas, a shortage of medical examiners is bound to exist. Encouraging practitioners to become certified (especially those already performing DOT physicals ), is an important goal for the FMCSA right now.
Personally, as a physician performing these exams for more than 5 years prior to this new law, I think that it’s great that the FMCSA has, as been said, “raised the bar” for medical examiners. The Federal Aviation Administration (FAA) has had certification standards for health care practitioners performing flight medicals for years and there is no reason that the FMCSA should be any different. It will improve public safety since only trained and certified medical examiners will perform DOT exams, and it will also decrease the likelihood of unqualified drivers “doctor shopping” in order to get their certificate. Most practitioners that perform a lot of these exams like me, have already obtained our certification and even started entering the drivers that we examine into the NRCME database. Once everyone becomes certified, it should mean less phone calls from confused practitioners with question ranging from what the standards are to things as basic as to where can they obtain a medical examiner’s certificate for example. Since it may take a while for the FMCSA to meet their goal of 40,000 certified medical examiners nationwide, practice expansion is likely for current certified medical examiners. The FMCSA currently has a National Registry (NR) Champion Toolkit that started on December 11 2013. It’s a monthly teleconference where medical examiners will share their experiences with the new program and talk about ways to reach out to their colleagues who are not certified yet to increase awareness and to get them to help grow the National Registry by becoming certified. All are welcome to these teleconferences whether certified or not. I attended the first teleconference and practitioners from various disciplines (MDs, DOs, Chiropractic Doctors, Nurse Practitioners, Physician assistants) from various practices ranging from academics, occupational medicine groups, and private practices fielded questions and comments regarding their experiences with the NRCME.
Certified medical examiners will be required to maintain documentation as per FMCSA standards, follow all FMCSA administrative requirements, provide copies of Medical Examination Reports or medical examiner’s certificate upon request for periodic monitoring and audits. Medical examiners will also need to complete refresher training very 5 years and recertification testing every 10 years.
How does the trucking industry feel about all of this? Changes are naturally met with resistance sometimes, as may be evident in the third link from a Landline Magazine blog below.
Links:
2. **National Registry of Certified Medical Examiners (NRCME)
3. (Landline Magazine ) Who’s is going to give you your next DOT physical? Truckers want to know.
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