As the premier exam management program, 3bExam connects thousands of employers, employees, drivers, and providers from a wide range of occupational health services, including urgent care clinics, occupational health groups and medical practices. Learn more about the process in this guest blog on the Urgent Care Association Industry Perspectives newsletter.
When it comes to DOT physicals, too often Certified Medical Examiners are more focused on the outcome and issuing the driver a medical certificate than they are on completing a thorough exam and following correct procedures. The final determination is always in the hands of the provider and the “right decision” is mostly discretionary.
It is important to remember that before a driver can be issued a medical certificate, a proper examination must be performed according to FMCSA guidelines. Let’s review some basics.
First, whenever a driver presents for an exam they must be given a physical without discrimination and without any pre-qualification of medical conditions or issues in their health history or legal bias. Examiners cannot pre-screen drivers over the phone or in the waiting room prior to their exam or their completing their section of the MCSA-5875 medical examination report form detailing their health history.
When it comes to the driver’s health history it is important to remember that the driver should complete the health history section of the form independently and not collaboratively with the examiner or other healthcare professionals at your practice. The driver is expected to answer honestly and accurately and provide detailed comments regarding their health history in their own words. Once completed, they self certify and sign the form attesting to this so that the examiner may review the health history with them.
Once the examiner reviews the driver's answers and health history information, and after further discussion and clarification, they should note any changes, additions or comments regarding conditions that may affect the driver’s certification in the health history review section of the form. The examiner should not change any of the driver's answers in the health history section.
It is important to remember that the FMCSA expects the driver's health history to be documented with the actual answers and information provided by the driver which may not necessarily be accurate information. Keep in mind that you are not diagnosing or treating the driver as a patient; this is an independent evaluation and assessment of the driver's fitness for duty and as such your evaluation can only be based on the information provided. Don’t worry if the driver has answers like, “I don’t know the name of my medication” or if they answer no to the question related to high blood pressure - thinking that since they are on medication for hypertension they no longer have high blood pressure. Use the health history review section to document those corrections. By doing that, in the event of an FMCSA audit, you’re not only exhibiting your due diligence as an examiner, but you also have a record of the exact answers provided. Although in some cases, it can be misleading or at the very least incomplete, and as an examiner you can only be expected to uncover so much of the “truth."
Only after the entire examination is completed -- including vitals, eye exam, hearing test, urinalysis, and the examiner's hands-on physical, the examiner should then evaluate all information at hand and decide if they have enough information to make a final determination. Examiners may order additional testing, ask the driver to perform additional functional capacity or agility tests, request a letter from a prescribing physician or treating physician in an effort to make the best decision possible.
The examiner’s role is to ensure that only healthy, capable drivers are on the road for a period of time that is reasonable. It is not the job of the examiner to find a way to get the driver certified, but to make certain that they meet the standards. This puts the examiner in a difficult position sometimes as they are forced to disqualify a driver which takes away their livelihood but that is what you sign on for when you join the National Registry of Certified Medical Examiners. Taking too much latitude or giving the driver the benefit of the doubt because you feel guilty charging for an exam without issuing a medical certificate could have dire consequences. Ultimately, the liability falls on the examiner.
Another important thing to remember is that whenever a driver presents for an exam you must report something to the FMCSA by the end of the following calendar day. Whether the driver meets standards for a two-year card, meets standards with periodic monitoring, does not meet the standard, or if the determination is pending, is solely at the discretion of the examiner with the exception of diabetes, seizures, vision and hearing. There is no recipe book or magic formula or even a handbook with specific requirements based on certain conditions, contrary to what you may see or hear elsewhere. If for whatever reason the examination was unable to be completed once started (in many cases drivers will walk out if they feel they are not going to be certified or may refuse to provide a urine specimen,) it is important to report an incomplete exam.
In closing, 3bExam works with hundreds of examiners on a regular basis and our team of experts speak with examiners daily that are either confused or misunderstand the basic procedure of completing a proper DOT physical exam. The FMCSA Is less concerned about determinations but very concerned about documentation. Too many exams go unreported and drivers are “doctor shopping” at higher rates than ever. FMCSA audits very often find medical examination reports that are incomplete or improperly documented making it difficult to discern what actually happened or in some cases if the exam even occurred. The certified medical examiner provides a key role as an extension of the FMCSA and must always act in the best interest of public safety rather than the interest of the driver, the transportation company, or own their own financial interest.