Commercial Driver Medical Examination| Rules and Regulations

Better DOT Physicals with Technology

Part III

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First off, no amount of technology will of course replace skills gained through professional training and experience, and the clinical judgment needed to perform safe and compliant physical examinations.   That is probably one reason given by some practitioners who are reluctant to digitize even partially or at all, any part of their daily encounter with patients.   Concerns about the “downtime” to learn how to do things differently and to train staff, as well as concerns about expenses required to procure and maintain new technologies are other common reasons given.  However, these reasons are becoming less important and less practical and dare I say, less fashionable in this rapidly evolving world where information can be shared almost instantaneously everywhere.

In the medical profession itself we find ourselves in a bit of an irony- With modern research and clinical advances highly dependent on computerized and advanced technologies, there are still many practitioners documenting patient encounters with paper charts.  Much of the concept for electronic health records (EHR) was developed in the 1960s and 1970s in industry, government organizations and academic medical centers, and today, most would say that we have made great strides, and are in the midst of a wide expansion of this technology with the goal of having a nationwide EHR system .  It is also becoming more affordable to develop your own office based EHR. The Federal government fully supports this and the Medicare and Medicaid EHR incentive programs provide a financial incentive for achieving  meaningful use, which is the use of certified EHR technology to achieve health and efficiency goals.  (This program is currently in it’s second stage).   In some states, the legislature is requiring mandatory electronic prescribing by physicians.  In New York the effective date for compliance is March 27, 2016 (March 27, 2016 is an amended extension of the deadline by the state legislature as many were not prepared to comply).   So the Federal EHR is an incentivized program and the NYS Electronic Prescription System (can be a stand alone e-prescription system or part of an EHR) is compulsory.   With paper prescriptions pads soon to become obsolete in New York, what’s in store in the future for hand written charts and manila folders if we are to achieve the greater goal of a national EHR system?   In fact the Federal government has moved to it’s next phase, from giving incentives to now penalizing eligible practitioners not attesting to using EHR, by reducing their medicare reimbursement incrementally each year.  

So what about medical examiners listed in the NRCME who are tasked with recording, documenting and storing driver examination encounters for 3 years and subject to FMCSA performance and compliance audits?   Busy examiners can easily get buried under paperwork, as trucking companies and fleets already know with the FMCSA Compliance, Safety and Accountability Program.   Maintaining proper vehicle and driver qualification files has become so time consuming that many trucking companies are now delegating the task to third party administrators as was recently reported in the Commercial Carrier Journal.    The penalty for non-compliance is significant, with trucking companies facing significant fines and possible shut down.  Medical examiners on the other hand will be removed from the National Registry for non-compliance (see Part II of this series, “What FMCSA Requires of Certified Medical Examiners”).  

Medical examiners can only use the approved MCSA-5875 Medical Examination Report Forms and the MCSA-5876 Medical Examiner Certificate when performing all driver qualification examinations.   The FMCSA has already automated the final step of the driver qualification process to some degree, by requiring  all medical examiners to record results of driver certification determination or outcome on the online MCSA-5850 form.  Failure to do so would again cause a medical examiner to be out of compliance.   So again, it does seem ironic, that an examiner would record the whole evaluation and physical with pen and paper and at the end log onto a computer to enter the results electronically.  

Fortunately, there is software currently available that can help medical examiners be more efficient and precise when entering driver physical examination findings and certification results prior to uploading it to the MCSA-5850. This sort of software can help medical examiners and clinics decrease errors, provide better record keeping and safer long term storage.   This is extremely valuable because even the most meticulous clinician may not survive an audit with poor record keeping, and matters can only get worse if there is an investigation.  Several such software exist (I haven’t reviewed or tested them all yet), and they seem to cater to various degrees either to the trucking companies and fleets or to the occupational medical practices and individual medical examiners.  The most comprehensive ones like 3bExam and Certadrive  are highly adaptable to suit the needs of any size office or organization that perform or order DOT physical examinations. As my own practice primarily sees independent drivers and small owner operators, I found 3BExam perfectly suited to the task.  I have been using it ever since and could not imagine ever going back to doing DOT physicals the old fashioned way.  It fitted right in with my office EHR and electronic prescription system.   Even if you are a practitioner who is exempted from the incentivized EHR program or compulsory e-prescription, it still makes sense to digitize your medical records for the reasons previously mentioned.   Other reasons often cited for preferably using electronic record keeping besides decreased errors and safer long term storage is legibility issues with reading charts, quicker data retrieval, facilitated sharing between laboratory, diagnostic facilities and other practitioners, as well as reporting to payers, insurance companies, and government agencies.   Furthermore, there is the opportunity for data mining, to render better and more efficient care and to reduce costs.  All this is is also relevant to the applications and software that enable medical examiners to perform better DOT physicals with technology.

3BExam in a very short time has established itself as a leader in this category of electronic DOT physical software companies, which includes not only the aforementioned Certedrive, but also Road Ready, Drivermedcert, and the DOT Tester.  If I have left out any other software companies out there, please forgive me.  I had the opportunity to test 3B’s software many months ago and have been using it daily ever since.  The Certedrive software was recently introduced to me, and as far as how the rest of the field stacks up, that will hopefully be a different review for another time. For now, what 3BExam offers can not only improve the speed and accuracy of the DOT certification process for examiners, but provide drivers and motor carriers with a more efficient and streamlined experience when they come to your office.  

With 3BExam you can use any internet browser with any computer, laptop, tablet or even a smartphone to access a user interface to enter your history and physical examination findings.  When an examiner logs in, the home page appears and there is a dashboard on top that displays recent news including any significant FMCSA examiner notices.  There are various task bars with drop down menus to jump to and open different fields, or you can just use the add employee or exam icons or use the search icons for quicker access.  The second half of the home page displays the number of exams you have (scheduled, ready, pending, on hold, or completed) in a color coded bar and graph scheme that can be particularly useful.  It gives you a quick picture of what’s going on now in your clinic and reminds you of important documents or tasks that you need to attend to or resolve.  To fill out the medical examination form electronically, the examiner opens an icon (currently 649-F) and is provided with a series of tabs that mirrors the familiar pages of the paper form labeled:  Driver’s info, Health History, Examiner Comments, Vision, Hearing, BP/Pulse  Rate, Lab Tests, Physical Exam, Certification, Complete, and Final.  One criticism I may have here is that perhaps they can reduce the number of tabs.  Sometimes I find myself jumping around more than I should between the Blood Pressure Tab and Lab Test Tab for example, and wondering if it would have been better to place them together.  But I do think that it was intentionally designed this way to prevent examiners from forgetting or omitting data, since you can not save any of the  tabs unless all the required fields are completed.  It is part of their error checking and alert system to help examiners avoid making errors of omission.   Anyhow, if an examiner wants to, he can just use the Summary tab to avoid jumping around.  

An important feature and perhaps a decision maker for many is the ability of the 3BExam software to automatically upload your DOT certification results to the online MCSA-5850.  It’s what some in the computer industry might call a “killer app function”, and for many potential customers it could prove to be a deciding factor.  After all, what’s the point of documenting all your history and physical examination findings electronically and still have to separately log on to the NRCME website to upload your certification results.   3B Exam has simplified this crucial and important final step by fully automating the process, allowing auto reporting of completed and “No exams performed” in real time. It’s the only company that I am aware of that currently provides this feature, and that alone will save the medical examiner significant time and expense and allow him to remain compliant, while not having to put his office staff to the repetitive task of keying in results manually into MCSA-5850.    3BExam provides error checks, reporting and auditing as previously mentioned, and also prompts examiner to review entries for certain nonsensical errors (since human errors of keying in can never be completely eliminated).   But with smart technology programmed to use logic, if you inadvertently enter driver systolic blood pressure as zero you will thankfully be alerted of this “foolish” error (naturally the driver will need the attention of a different type of “medical examiner” and not one from the NRCME if he really has no blood pressure).  The electronic cloud storage feature allows you to not only save space and paper, but provides safer long term storage that can extend far beyond the required 3 year period if desired.  Other important and useful features are document management (allows you to enter supporting documents such as clearance letters to attach to driver’s electronic file), and company portal (allows your companies  to access their driver information through their own portal).  Overall the 3BExam’s software flows seamlessly.   It doesn’t interfere with the speed or ease an examiner already possesses in performing DOT physicals, because it does not force too many added features that may prove more useful to new examiners, but a hindrance to more experienced ones.

Electronic health records (EHR) have become a necessity in our modern times, and they are much more advanced now compared to their predecessors from decades ago. For DOT physical examinations 3BExam offers similar advantages as other electronic medical records used by practitioners in their general practice.  In the future they will not only offer electronic documentation for DOT physical examinations but also:

solutions for occupational health professionals to manage a wide range of exams tests and screenings”.

So what are you waiting for?  Prices for these type of software vary, and some like 3BExam offer a set monthly fee (currently $99.00) for uploading unlimited examinations and to use all of it’s features.  Other companies may have other fee structures based on volume (i.e. the more exams you do the cheaper) and may even charge for additional services or options that you choose to activate in the software.  In future articles with more information available, hopefully a side by side comparison of the different software options will be possible.  

In the mean time, there is no reason to wait because the future is here now, and come April 20,2016 as all medical examiners know, the revised forms MCSA-5875 and MCSA-5876 will replace the current forms.  The new forms contain more questions, and as a result of the Medical Examiner’s Certification Integration Rule they must be used “as is”.    Prior to this Rule examiners were allowed to record results “substantially in accordance with” the examination forms provided, but starting April 20, they will be out of compliance if not recorded “as is”.

So throw away your paper DOT physical examination forms and your manila folders (if they are more than 3 years old of course), or scan them into your computer, and start performing better DOT physicals with technology.  You will relish the fresh air that now streams into your office when the giant steel file cabinets are gone.  Both driver and motor carrier will appreciate your efficiency, and reliability-and the FMCSA will hopefully appreciate your efforts too!

 

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