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?)


It depends.  If you temporarily disqualify for a short period just to have them update a consult or test, and you don’t need to do a full exam, you can either add the documentation to their previous DOT exam or make a new form and check “follow up” in the upper right, then just update the card from the date of the original exam.
If there is a significant change in their condition, e.g. they had surgery, a long hospitalization, disqualified because of sleep apnea and now on CPAP, I do a new examination and date from today.
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?
I’m not a legal expert, but my understanding of the business associate agreement is that it is meant for other businesses involved with rendering care to your patients that may have access to PHI, such as your lab, data, equipment vendors and the like.  Just a consent to release information to employer should be fine for releasing the long form.
3.       Any suggestions for what you use to encrypt and email with a DOT PE attached.
Great question — I don’t, unless you have an intranet that is HIPAA compliant that your client can access with a login.  Secure fax is OK.  We are working on an employer portal that the client can log in to securely, so they get an email with a link to their account, that would be HIPAA compliant.  Stay tuned for more info on this.
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.
Thanks, I didn’t know that.
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

Here is a short video of the evaluation and treatment algorithm for obstructive sleep apnea in commercial drivers:

Or access the full course here:

Obstructive Sleep Apnea in Commercial Drivers Course

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