1. If you disqualify a driver, and in 3-6 months they are able to return to work, present all documentation needed, and qualify. Do I date the card for the day they come back or retro it? (I dated it for the day they came back, was this correct?)
2. Under HIPAA is it necessary to have a business associate agreement with the companies that receive the DOT PE since it is part of the medical record?
3. Any suggestions for what you use to encrypt and email with a DOT PE attached.
4. Fyi: Virginia has a disability waiver for patients on insulin and also a waiver for drivers who do not meet the vision guidelines. They can only drive intrastate with the waivers.
5. I have patients that lose their original DOT card and return for another, is it ok to just make a copy of the one we have in the chart or do I need to recreate another original?
I’m sure a copy is fine, I usually have just made up a new one, just copying by hand, I think it’s your call.
6. The guideline for OSA: annual exam with annual sleep test or MSLT. Is annual compliance for CPAP ok by it self if they are compliant?
Yes, annual compliance report must show that they are using the PAP 4h/night, 5 out of 7 nights, <20 AHI, with no excessive daytime sleepiness (EDS) on history. If they are non-compliant, they should be disqualified until compliance can be demonstrated for at least a week, then I progressively increase their certification, 3 mo, 6 mo, 1 year as an example.
If you are not using home sleep testing in your practice for drivers (or any patients) and would like to, let me know.
Obstructive Sleep Apnea in Commercial Drivers
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