FMCSA Electronic Medical Card Filing Rule

As of June 22, 2018, according to FMCSA, truck drivers will no longer have to carry a Medical Examiner’s Certificate (MEC) with them or be responsible for submitting documentation to state agencies. medical examiners certificateInstead, the FMCSA’s electronic registry will verify the trucker’s current medical status.

The rule does not affect current medical exam standards or the qualifications of the medical examiner (ME) who performs a Department of Transportation (DOT) physical. Instead, it simply shifts the burden of reporting and recordkeeping from the driver or carrier to the ME performing the exam.

Process for Obtaining MEC Cards

Until the implementation date, truck drivers who fall under FMCSA medical guidelines must follow the current process. First, the driver locates an approved doctor from the National Registry of Certified Medical Examiners (NRCME) and schedules an exam. After the exam, the driver receives a Medical Examiner’s Certificate to prove they passed all requirements. These initial steps will not change after the rule’s implementation.

Non-CDL Driver Requirements
The burden of proof falls on the employer of non-CDL drivers. The driver must submit their MEC to the company. The employer must keep a copy of the MEC in the Driver’s Qualification (DQ) file for at least three years. Employers are also responsible for retaining verification that the ME who performed the exam is on the NRCME list. The new rule requirements have little effect on non-CDL drivers.

CDL Driver Requirements
Truckers who have a CDL will see the most changes once FMCSA implements the new rule. Currently, CDL holders are responsible for several additional steps to ensure their MEC is valid and on file with the state Department of Motor Vehicle office.

After receiving the MEC, the CDL holder has five days to submit a copy to the state licensing office. The state has a 10-day period to process the driver’s medical status and include it on his or her motor vehicle record (MVR). The driver is required to their MEC card during the 15-day period after the exam. Afterward, the MVR provides proof of the driver’s medical status.

Requirements for Employers and Motor Carriers
As with non-CDL drivers, employers and motor carriers who work with CDL drivers must keep the same records in each DQ file:

  • A copy of the driver’s MEC for 15 days after the exam
  • Proof the medical examiner who performed the exam is listed on the NRCME
  • A copy of the truck driver’s MVR after the initial 15-day period

Owner-operators should retain copies of these records for their own protection and reassurance. If drivers are pulled over or questions arise, the information is readily available and does not require contacting one or more carriers to track it down.

Differences with the New Electronic Medical Card Filing

When the electronic filing regulation takes effect on June 22, 2018, all drivers who need a MEC will still find an ME on the registry, have a physical, and receive a Medical Examiner’s Certificate afterward. From that point forward, CDL holders will benefit the most from the streamlined process.

Changes for Truckers
Instead of the CDL driver submitting information to the state, the medical examiner must upload the MEC to the FMCSA database. The medical examiner has until midnight of the day following the exam to submit the relevant information to the FMCSA. The agency then transmits this relevant data to the Commercial Driver’s License Information System (CDLIS). States use this system to update each driver’s motor vehicle record.

Since the MVR is updated within a few days of the exam, truck drivers do not have to carry a copy of the MEC. Drivers also do not have to worry about taking time off work to submit their MEC to the state division of motor vehicles (DMV).

Changes for Employers
Since the upload will originate from a specific NRCME-registered medical examiner, carriers and employers of CDL holders will no longer keep track of which medical examiners are on the registry. There is also no reason to retain a copy of the MEC since the new system updates the driver’s MVR quickly.

Medical examiners will upload MECs to the database for every exam, regardless of whether the driver holds a CDL. However, employers with non-CDL drivers must still retain documentation proving the ME is on the national registry and a copy of the MEC in the Driver’s Qualification file for a three-year period.

Adjusting to the New Regulations

When the final rule takes effect, it will significantly reduce paperwork for CDL drivers and employers, as well as carriers who contract with CDL owner-operators. However, it may be a good idea to carry the appropriate documentation for a few weeks after the June 22, 2018 implementation deadline. If the system glitches, you will have documentation of your MEC and DQ file information to verify your medical status.