Most Frequent Questions about DOT Medical Cards
posted in Alerts by Brian Gray
Most Frequent Questions about DOT Medical Cards
Written By Lucas Kibby, CleanFleet
The Federal Motor Carrier Safety Administration (FMCSA) requires all drivers of commercial motor vehicles (CMVs) to pass a FMCSA physical to obtain a DOT medical card.
Beyond traditional trucking companies, construction companies, local delivery, moving companies, people transportation of 8 to 15 passengers, and distribution companies that are transporting goods in delivery sized trucks instead of larger semi-trucks qualify to get a medical card.
Because of this large group of people needing medical cards, we are finding that medical card questions are baffling those responsible for qualifying commercial drivers. Below are seven of the most frequent questions about DOT Medical Cards, according to J.J. Keller.
Which drivers need a Federal DOT medical card?
The short answer, drivers operating MVRs. Part 390.5 of the FMCSRs defines a CMV as any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle:
- Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 10,001 pounds or more, whichever is greater; or
- Is designed or used to transport more than 8 passengers (including the driver) for compensation; or
- Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or
- Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C.
Does a driver need a new physical after returning from a medical leave of absence?
A driver’s medical card needs to be renewed every two years. If there is time left on a driver’s medical certification, the FMCSA leaves choice of recertification to the motor carrier. But, if a driver’s medical qualifications come into question at any time, the driver is supposed to go in for a new exam based on Section 391.45(c). Only a certified medical examiner has the authority to declare a driver medically unqualified.
Do we need a non-CDL driver’s motor vehicle record (MVR) as proof of a physical?
No, a non-CDL driver’s current medical status will not appear on his or her motor vehicle record (MVR). Federal regulations only require state driver’s licensing agencies to monitor and track the medical status of CDL drivers that have self-certified as “non-excepted” interstate or intrastate drivers. Non-excepted simply means they are subject to driver physicals.
Do we need a new MVR after each driver physical?
Yes, CDL drivers need an MVR within 15 days of any new driver physical. This includes medical cards issued for short durations. For example, if your CDL driver is given a three- or six-month medical card, you must have an MVR in the file as proof of medical qualification each time the driver goes back for recertification.
Do we need to retain a copy of the federal medical card in the Driver’s Qualification (DQ) file?
For non-CDL drivers, you must keep a copy of the fed med card in the file for three years following the exam, along with a note that you verified the status of the medical examiner on the National Registry of Certified Medical Examiners (NRCME).
For CDL drivers, you would only retain the federal medical card as temporary proof in the DQ file until you receive an MVR reflecting the newest exam. You must have this MVR in the file within 15 days of the exam, along with a note that you checked the NRCME for the exam. Both the MVR and NRCME note are kept for three years.
Does the medical examiner provide a copy of a CDL driver’s medical card to the state on the driver’s behalf?
No. CDL drivers must continue to submit a copy of the medical card to the state of licensing. If your medical examiner has stopped issuing federal medical cards to your CDL drivers, this is in error. The driver needs a copy to submit to the state, and both the driver and employer need a copy as temporary proof of medical certification until it appears on the MVR.
Is sleep apnea discussed in the federal regulations?
Yes, however briefly. Sleep apnea is mentioned in “Appendix A to Part 391—Medical Advisory Criteria.” The standards used by certified medical examiners are not a part of the federal regulations. Instead, they are included in guidance materials provided to medical examiners by the Federal Motor Carrier Safety Administration (FMCSA).
Before you choose a medical examiner, ask yourself these three questions:
- Am I OK with a physician telling me that one of my drivers or potential drivers is not fit to drive?
- Am I willing to either work with that driver to get him fit or to part ways with the driver?
- Is ensuring the safety of the driver and other drivers on the road more important than just certification and approval?
If you answered “Yes” to all three questions, you may want to use CleanFleet as your resource for DOT medical exams. Trust, honesty, no conflicts of interest, and a commitment to safety – this is what makes CleanFleet different.
Learn more about CleanFleet’s DOT Medical Exam service or schedule an exam for yourself or a driver.
***Doris Bean*** says: posted on 14 Jul, 2017
What drives me crazy is that drug screens do not look at the amount of prescription levels in a driver’s system at the time of a pulled random. Another local issue is that a CDL driver can be moonlighting at two jobs. One job he comes up dirty. They offer the S.A.P.. etc. Employee quits on the spot. Neither company is aware the employee is working at both locations. Big loop hole in State regulations.
***Brian Gray*** says: posted on 17 Jul, 2017
Thank you for your comment. We completely agree with the “loopholes” our there today. But some additional comments: Prescriptions are handled by the MRO. If a driver has a valid prescription, MRO will result a negative. Drivers are also responsible for notifying all employers of positive. This is something the DOT Clearinghouse will fix.
***Callum Palmer*** says: posted on 21 May, 2018
This was a fascinating read and I have to admit that I had no idea that there was so much to know about the DOT physical. My brother is looking to become a truck driver, so I’ve been helping him do a bit of research on the topic. I am especially surprised to learn how it can be determined after a leave of absence; although, I suppose that that would make sense for safety reasons.
***Brian Gray*** says: posted on 23 May, 2018
Thanks for checking out our resources. Reach out to us if you have any questions. For DOT trucking compliance for starting up, be sure to check out our sister company: https://www.glostone.com/solutions/startup-services/compliance-starter-kit/ . We can walk your brother through this whole process and make sure he is in compliance!
***Bobby*** says: posted on 04 Mar, 2019
So I went to get A DOT Physical card this morning and was told it was put on hold because I failed a non-Dot pre-hire urin analysis at the beginning of last yer. I have been told a couple of times that I will have to undergo a 3 month SAP program to be able to drive. What are the facts?
***Brian Gray*** says: posted on 04 Mar, 2019
It most likely arises from the federal medical form you filled out…
All CMV drivers are required to pass DOT physicals in order to get their medical cards, and their physicals must be conducted by a Certified Medical Examiner (CME). Part 391 of the FMCSRs state that the use of Schedule 1 drugs by a driver is an automatic disqualification from operating a CMV. There are two ways that a CME can disqualify a driver for using Schedule 1 drugs:
The first way is when a driver admits use on the “federal” form s/he fills out before the physical. The form the driver fills out for the medical examiner asks two questions about illegal substances.
1. Have you used an illegal substance within the past two years?
2. Have you ever failed a drug test or been dependent on an illegal substance?
The first question is referring to any federal Schedule 1 drug, including marijuana. If the driver marks “Yes” to the first questions, they are automatically disqualified and will not receive the required medical card.
If the driver marks “Yes” to the second questions (which is referring to failure of a Schedule 1 drug), the diver is not automatically disqualified, however, some medical examiners may want the driver to take a non-federal drug test.
In the second scenario, if the medical examiner notices symptoms of potential drug use, they can request a drug test before passing the physical. This type of request is similar to any other type of request a CME may make before issuing a medical card, such as a sleep study for sleep apnea.
You could always ask your physical examiner if you could take a non-DOT drug test instead of the SAP program. If you hop around to another CME, you may get flagged for doing this and could bring more negative attention to your situation.