Contributed by J.J. Keller & Associates – October 28, 2015

‘Planning Ahead’ Rather than ‘Reacting To’

The CDL/Fed Med card merger and the process to be medically certified to operate a commercial motor vehicle (CMV) is still experiencing some bumpy roads, and not only for motor carriers. Some drivers, medical examiners, and even some states are still having problems with the process. While these problems are getting worked on to make this renewal process smoother, there are some planning steps the motor carrier can take to ensure their operation is not interrupted.

The first step a proactive carrier can take is to send drivers in for their physicals as early as possible. This will be very helpful to all parties concerned if the information the state has on file expires. If a problem with records appears, corrections can be made before the old information expires. Keep in mind, once information expires, the driver is considered medically unqualified.

If need be, instruct your driver to “hand deliver” the new medical card to the licensing agency immediately upon leaving the examining location. Have the driver get a receipt if possible.

Ask the driver to carry the new medical card all the time and not for only the 15 days as stated in the regulations. Reason is, if an officer runs the driver’s license, and the medical information is not valid, the officer will accept a new medical card for the first 60 days rather than the just the required 15 days. This is provided the driver’s CDL has not been downgraded. If so, the driver will be placed out of service even if he/she has a valid medical card issued in the last 15 or 60 days.

If the process seems to have gone smooth and everything seems to be in place, run an MVR 10 to 12 days after the exam to be safe. The state has 10 days to post the information and the carrier can use the card for 15 days. If the exam information is not on the MVR and the driver’s previous physical has expired, the driver is not medically qualified as far as the state is concerned. Contact your MVR vendor, whether it is the state or a third party, and verify that they have sent you the correct type of MVR. Also, contact the driver and verify that the information was submitted immediately after the physical. If so, instruct the driver to contact the state licensing agency immediately and clear up the issue.

The fact is, if the driver waits too long to get his/her physical and was then late in submitting the information, the driver may end up being downgraded and must be immediately removed from operating CDL-required vehicles. Basically, when a driver is downgraded, he/she has no CDL and you are now a driver short in your operation!

Regulatory Alert

Make sure your medical examiners are using the correct medical forms after Dec. 21, 2015! Beginning on Dec. 22, 2015 (but no sooner), examiners must use a new Medical Examination Report Form, known as the MCSA-5875 (the long medical exam form), and a new Medical Examiner’s Certificate (medical card), the MCSA-5876. Forms that are currently in use may not be used after Dec. 21, 2015, even though the old and new forms are substantially similar.