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Status Quo for DOT Medical Exams is Changing

The National Registry of Certified Medical Examiners rule was published in April 2012 and effective in May 2012. A compliance date of May 21 of this year is quickly approaching. In its plainest form, it is a database of medical examiners who are certified by the Federal Motor Carrier Safety Administration to perform examinations of commercial vehicle drivers.

by Rick Malchow, J.J. Keller
April 8, 2014
5 min to read


Bob is a good driver. He has a million safe miles, has been with the same carrier for more than 10 years, and is appreciated by his customers, dispatchers, managers and peers. His years have helped him develop sound habits.

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Bob’s med card expires in early June. He had an appointment set for late May for his regular physical and expected the doctor to sign his DOT card like normal. Because he always used the same provider, he didn’t mention that his DOT med card was expiring as well.

His physical found no problems, the doctor only had her customary caution that Bob could lose 20 or 30 pounds. At the end of the physical, Bob asked for his updated med card. The doctor apologized – she assumed that Bob knew that not all medical providers could certify that a driver was medically safe to drive anymore.

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The government now only recognized exams from medical professionals that were listed in the National Registry of Certified Medical Examiners. Bob was surprised, disappointed and more than a little concerned. His card would expire in just a couple of days and without it, he would not be able to drive.

The new rules

The NRCME rule was published in April 2012 and effective in May 2012. A compliance date of May 21 of this year is quickly approaching.

In its plainest form, it is a database of medical examiners who are certified by the Federal Motor Carrier Safety Administration to perform examinations of commercial vehicle drivers.

The “physical qualifications and examinations” requirement for drivers is listed in Subpart E of Part 391 and encompasses Sections 391.41 through 391.49. A general medical practitioner may have skill diagnosing and treating disease and likely understands many of the terms used in the sections. However, he or she may not have a handle on all of the duties of a driver.

Examiners must now be trained on the FMCSA’s physical qualification standards by a nationally recognized medical-profession-accrediting organization and pass a certification test. They can then apply online using the National Registry System to receive a unique identifier.

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The MEs report the results of exams every month using the National Registry System. To continue being a certified and registered ME, the professional completes training every five years and needs to pass the Medical Examiner certification test every 10 years. MEs have been able to become certified and join the registry since May of 2012.

The rest of the story

Bob’s company couldn’t afford to lose him. They had a list of examiners they used in the past. His dispatcher, Mary, called every provider on the list. She found two registered MEs, but they could not work him in for several weeks.

When Mary finished the list, she called back one of the listed providers to find out who else might be able to work Bob in before his card expired. The office representative explained that the providers are listed and searchable on the registry’s website: https://nationalregistry.fmcsa.dot.gov. Mary quickly checked the list, finding only the two she had already called.

Not to be stopped, Mary started checking the database for every city on their most common lanes. She found one who had just had a cancellation and could see Bob tomorrow. Mary dispatched Bob on a run that would accommodate the appointment.

The exam proceeded with the standard listening to Bob’s heart and lungs, checking of his blood pressure, eyes, ears, reflexes, and weight. Bob was surprised, though, at some of the questions asked during the exam. There was the usual about his weight, but that proceeded quickly into questions regarding how he sleeps.

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“Do you snore?” Yes.

“Do you sometimes wake gasping or startled?” Yes.

“How often?” Just once a week or so.

“Do you feel like you need to stop and take a nap mid-day?” Yes.

At the end of the exam, Bob was surprised to receive a certification for only three months. He was given instructions to have a sleep study done and received a pamphlet on sleep apnea.

What does the FMCSA hope to gain?

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The FMCSA hopes to achieve two primary goals: improve highway safety and improve driver health. They say this can be accomplished by “requiring that medical examiners be trained and certified to determine effectively whether an operator meets FMCSA physical qualification standards.”

The new regulation does not change the biennial frequency required, and as before, MEs can insist on a more frequent cycle to address chronic or acute conditions. An examiner who has a keen eye on what the day of a driver consists of will stay tuned to drivers’ health and the effect on CMV operation.

It’s hard to argue that a healthier driver pool will not have a positive impact on overall safety.

What’s next?

The rule also dovetails, but is not directly tied to, the med card/CDL merger rule. Both rely heavily on an automated and electronic process that replaces labor-intensive paper systems.

In addition, another rule concerning medical examinations and MEs was proposed in May of 2013, Medical Examiner’s Certification Integration, which will take the automation one step further.

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Carriers and drivers need to be aware of this change and begin the search now for medical examiners that are certified and registered. There is a concern that there are not enough providers in the registry, and the hope is that the number of providers will grow with the need. Finding a certified ME will be more of a challenge for drivers in the first months of the program.

Drivers should be aware that due to the significant training specific to the operation of a CMV, examiners will more likely hone in on health issues and how they relate to real on-the-job requirements. If carriers have preferred provider lists for the exams, the list will need to be updated.

The key takeaways are to know what has changed with medical examiner requirements and plan ahead.  

Rick Malchow is a Transportation Management Editor for J. J. Keller & Associates. Prior to joining J. J. Keller, Malchow worked in the transportation industry for 13 years, spending much of that time in operations management.

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