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 medical examiner’s (ME) qualifications who performs a Department of Transportation (DOT) physical. Instead, it simply shifts the reporting and recordkeeping burden 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 their motor vehicle record (MVR). The driver is required to have 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.

DOT Physical Requirements for Medical Cards

All drivers must comply with federal law and have a DOT physical completed by a doctor, physician’s assistant, or nurse practitioner. There are a few things the medical professional will check for during your physical. Below are some of these things:

  • Your blood pressure and pulse
  • Vision test
  • Hearing test
  • Check for spine deformities
  • Check mouth and throat
  • Neurological exam
  • Listen to your heart
  • Check abdomen for any abnormalities
  • Check for hernias
  • Conduct a urinalysis

All these things are checked because, in order to pass your DOT physical, you must be healthy. Some requirements of the DOT physical include:

  • Have at least 20/40 vision in both eyes or at least 20/40 vision in either the right or left eye.
  • A clean drug test from cocaine, amphetamines, opioids, THC, marijuana, and PCP.
  • Pass the hearing test with being able to hear five feet without using a hearing device.
  • Pass the neurological screening without any concern for epilepsy, brain injuries, or seizures.
  • Pass the healthy heart screening and have no history of heart disease, or any medical illness that could cause sudden death while operating a commercial motor vehicle.

Differences with the New Electronic Medical Card Filing

When the electronic filing regulation took 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 MEC copy. 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 quickly updates the driver’s MVR.

Medical examiners will upload MECs to the database for every exam, regardless of whether the driver holds a CDL. 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 three years.

Since the final rule went into effect, this has significantly reduced paperwork for all CDL drivers, employers, and carriers who contract CDL owner-operators.

All CDL holders should remember to keep an updated copy of their MECs for any reason they are questioned about it during a stop.