Should you be both the DOT medical examiner and the PCP?

Omar asks:

I just finished listening to your webinar on the new DOT form. It was quite informative and useful. I still need to go back and brush up on the determination pending part.
I have a question for you: in your webinar, you stated that the ME can recommend or even order a sleep study but not make the diagnosis or treat the disease. That has to be done by another provider.
Now what about the driver who comes to you for DOT exam and who has uncontrolled or untreated stage 2 or stage 3 high blood pressure.
Is it allowed for the ME to stop the DOT exam, and then see the driver for his high BP and prescribe medication for it?? ( as a separate office visit)  I am sure this is a very common scenario for many ME’s out there. Your answer would be appreciated.

Is it allowed for the ME to stop the DOT exam?

  • MEs are supposed to:
    • complete the exam on every single driver, no matter what condition becomes evident or what that will mean for possible disqualification
    • then make a determination –
      • qualified for a full 2 year certification
      • qualified with restrictions
      • qualified only accompanied by a waiver/exemption
      • disqualified
      • or the two “new” options,
        • determination pending, which gives the driver 45 days to provide additional information, and
        • incomplete exam, where for whatever reason the examination is not completed and no determination can be made.
  • If you say something like “oh your blood pressure is way above the acceptable range for DOT, you can’t get qualified with that blood pressure reading ( or any other potentially limiting condition)” the driver may also refuse to continue the exam and go out and try to find another examiner.  This gets back to “doctor shopping” which is among the practices the NRCME sought to eliminate.

<Should the> ME see the driver for his high BP and prescribe medication for it? (As a separate office visit)

 For a long time I was the “company doc” for our local trucking companies, including the hubs for many well known carriers like UPS, Fedex, Yellow Freight, ABF and on and on.  And yes, in our urgent care/occmed practice we often wound up seeing these drivers for these medical conditions that came up on the commercial driver exam (in a separate visit) and would wear those 2 hats – Medical Examiner and Primary Care Physician.

Some of these drivers became my patients for years and brought in their wives and kids to see us too.  This was actually a gratifying way to grow our practice and maintain a great relationship with the drivers/patients and the client company.

FMCSA does not prohibit this practice, but one of the intentions of the NRCME is to avoid the “oh by the way doc, sign my card” type of encounters, and to focus on the commercial driver medical examination as a distinct fitness for duty evaluation, performed by specially trained, certified examiners, separate from the primary care visit.  The certification process has eliminated many primary care practitioners from the medical examiner pool if this was not a big part of their practice worth getting the training and certification for.

Medical Examiners should:

  • Complete the entire DOT exam and make a determination


  • Best practice, in my opinion is to refer the driver to their own PCP if they have one, for any needed evaluation, follow up, adjustment of medication, needed testing, etc, and to have that report sent or brought in to you.


  • If the driver does not have a physician, and something comes up during the DOT exam that warrants an evaluation, refer them to a local primary physician.  In fact, if you are in an urgent care or occmed practice and don’t offer primary care services, this is a great way to get referrals back for DOT exams and other urgent care or occmed services from area physicians who don’t provide those services.

If you want a sample letter to send to area docs –  get it here!

  • If you wish to offer the primary care services in your practice, I recommend having a co-worker provider see the driver for the medical condition, and you keep the “medical examiner hat.”


  • If you do wind up seeing the driver yourself as both the medical examiner and the PCP, make it very clear that these are completely separate visits from the DOT exam and you are not in a position to do any “favors” by overlooking or ignoring regulations and guidelines.  As the ME, you still have responsibility for public safety.