FMCSA AND URGENT CARE

Over 90% of urgent care centers provide some type of occupational medicine services.  These services typically include drug screens, employee physicals, worker’s compensation injury care and other testing and specialized exams.  Among the most common are Commercial Driver/DOT exams.  Many of the same advantages of extended hours and accessibility that attract patients to urgent care also appeal to both drivers and their employer motor carriers, and minimize the impact on lost time.  Motor carriers have long relied on urgent care centers that focus on occupational medicine to be more knowledgable regarding FMCSA regulations for commercial drivers than the typical primary care physician.  With the advent of the NRCME rule, there has been a further, necessary migration of exams from non-certified primary care physicians to certified examiners many of whom are associated with urgent care centers.

DOCTOR SHOPPING

One of the goals of the FMCSA in creating the NRCME is to prevent so called “Doctor shopping,” whereby a driver might fail their certification or be required to obtain needed medical diagnostics or treatment under a temporary certification, only to go to a different examiner hoping for a pass.  When the motor carrier requires the exam to be done by a known qualified examiner, this practice is obviated, as the same examiner or another in the same group has access to previous records and reasons for disqualification or temporary certification.  If the driver is disqualified, the new procedure is that the driver is supposed to be listed on the national registry as such. If the driver remains in control of selecting the examiner and If he/she goes to another examiner and passes, and is again listed on the registry now as passed, the officials at FMCSA are now alerted that something is amiss and will intervene.The missing link here is that second examiner, if in another practice not associated with the first examiner, does not currently have a way to query the registry as to an individual driver’s certification history.  So if the driver now omits significant past medical history or symptoms previously under scrutiny, the second examiner has no good way to know what the first examiner was concerned about or what further evaluation was required.  When the driver has significant examination findings this is less of a problem, but often it is a medication omitted (phenytoin, narcotics, coumadin, etc) or recent hospitalization for a serious condition which may not be evident on exam that is “forgotten” once known it will affect their certification.

CERTIFIED MEDICAL EXAMINER DILIGENCE

Of course there will still be those examiners who lack the level of diligence and adherence to regulations and guidelines that would be expected of a certified examiner.  Another of FMCSA’s goals is to identify these examiners and institute disciplinary (and hopefully educational) procedures, eventually resulting in delisting from the registry if corrective measures aren’t successful and unqualified drivers are repeatedly given inappropriate certifications.Perhaps the registry will evolve to include a query function, much like many states’ current narcotics databases, so all examiners will have access to any previous certification and medical issues or requirements for additional testing.

DOT EXAMINER NETWORK

In the absence of that function, some of us in the urgent care industry are considering some coalition or association whereby we have some manner of shared record keeping on our DOT exams to maintain consistency and quality in following up on “less qualified” drivers.  Enabling this might be a shared “enterprise level” EMR system or some repository of exam results similar to but separate from the NRCME, perhaps facilitated by EMR interoperability.

Other advantages to such an endeavor would include presentation of a DOT examiner network of sorts to motor carriers made up of member urgent care centers and other certified examiners who collectively hold themselves up as adhering to the more diligent side of performing these examinations.  This might include an internal quality control mechanism such as chart/peer review or again, EMR enabled/facilitated quality measures and protocols, much like that required for governmental meaningful use (MU) and other quality based incentive programs.  Just as easily as we might now be prompted to offer colonoscopy or smoking cessation interventions, we could be reminded that there needs to be a 2 month waiting period after an MI, tolerance to any cardiac meds with a cardiology clearance letter and satisfactory ejection fraction.  Such a system might also flag inappropriate certifications and have a reporting mechanism to measure outcomes and outliers.  Motor carriers would be more confident that their drivers are safe, reducing their own costs and liability, as well as helping to improve driver health by mandating follow up on needed medical care.

Urgent care centers with certified medical examiners will continue to play a vital role performing commercial driver examinations.  Convenient access to services on an extended hours, walk-in basis can be further enhanced by networks of urgent care centers and other qualified examiners aiming to optimize adherence to regulations and guidelines, communicating the exam results and status among examiners to avoid doctor shopping, monitor quality measures, and giving motor carriers confidence that their drivers are compliant, healthy and safe.

If you are involved in urgent care and are interested in becoming part of such a network, let me know:

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