The Federal Motor Carrier Safety Administration ("FMCSA") has recently issued a statement that a medical professional does not become a certified medical examiner until he or she receives a signed certificate and is placed on the national registry. The FMCSA provides that in addition to a medical provider passing a written examination, the agency conducts a thorough validation process before it will issue a signed certificate. The validation process includes ensuring that test results are accurate, that training has been posted and the medical professional’s credentials are current. A DoT medical examination performed before a certification is provided to the medical professional is considered invalid. There have been growing concerns that potentially thousands of drivers have undergone invalid medical examinations since December 1, 2017.
The FMCSA National Registry of Certified Medical Examiners website went down on December 1, 2017 and was “under construction” for at least five months. The website outage prevented medical providers, who passed their certification testing, from joining the national registry. These were doctors who had taken the necessary training and passed the certification test, however, could not legally perform DoT physicals because they could not be added to the registry. The FMCSA has continuously stressed that any physicals performed by a medical profession who did not have a written certificate and/or were not on the national registry is considered invalid. Those drivers would need to be re-examined immediately by a certified medical examiner to receive a medical card.
This leads to the questions of just how many new medical professionals jumped the gun and began conducting DoT physicals without a written certificate, or being on the national registry. The fear is that many medical professionals believed they were added to the registry after passing their certification and began examining drivers since December. It is unclear how many drivers may have been affected, but the carrier still has the obligation to ensure that a medical professional performing a DoT certification is properly certified and on the national registry.
There are other search tools available to help drivers, motor carriers and state driver’s license agencies verify that a health care provider is in fact certified and listed on the registry. Certified Medical Examiners can continue to conduct DoT physicals and issue paper Medical Examiner’s Certificates, Form MCSA-5876 to qualified drivers. Medical examiners are instructed to segregate all examinations completed during the outage and be prepared to upload them to the national registry system with no penalties when it is back online. Truck drivers, who are preparing for a DoT exam, can use the OOIDA website to read reviews on certified medical examiners.