Certified medical examiners (MEs) should understand the rights and options of commercial motor vehicle (CMV) drivers for obtaining a Department of Transportation (DOT) physical examination after disqualification. This is crucial for fair treatment, health and safety, legal compliance, driver retention, and advocacy. It promotes health, fairness, and safety on our roads and workplaces. If a medical examiner deems a driver unqualified to operate a CMV should the ME examiner be concerned that the driver will obtain a medical certificate from another ME?

The answer is No! Here’s Why

If a certified medical examiner (ME) deems a commercial motor vehicle (CMV) driver unqualified to operate a CMV, there could be a risk that the driver might seek a medical certificate from another ME. This is why it is crucial for MEs to not only understand the rights and options of CMV drivers but also to uphold the standards and regulations set by the Department of Transportation (DOT).

If a certified Medical Examiner (ME) determines that a driver is not physically qualified according to 49 CFR 391.41(b) (physical qualifications standards for drivers), they must inform the driver of this determination and explain why they are not qualified. This information is reported to the Federal Motor Carrier Safety Administration (FMCSA).

MEs play a vital role in ensuring the health and safety of our roads and workplaces. They must remain vigilant and committed to their responsibility, ensuring that only those who meet the health requirements are certified. This includes being aware of the potential for “doctor shopping” by disqualified drivers and taking appropriate steps to prevent such practices.

Furthermore: The National Registry of Certified Medical Examiners (NRCME)

Since May 21, 2014, the FMCSA requires that all healthcare professionals performing qualification examinations on CMV drivers and issuing medical certificates be certified and listed on the NRCME.

Certified MEs upload their results to the national registry within one business day. The physical qualification exam results of CMV drivers are submitted to the FMCSA via the National Registry. Consequently, if two different MEs upload conflicting exam results for the same driver, it would raise a significant concern, or a “Red Flag.” This situation underscores the importance of consistent and accurate evaluations by MEs to ensure road safety and regulatory compliance.

Interstate CMV drivers (drivers operating across state lines) must obtain their physical qualification examination from an ME listed on the National Registry and must comply with the physical qualification standards (49 CFR 391.41) outlined by the FMCSA.

-Drivers need to obtain a Medical Examiner’s Certificate (Form MCSA-5876) before operating a CMV (initial examination) and prior to the expiration of their current certificate (recertification examination).

-If there is a change in their physical or mental health status, they must obtain an updated certificate.

-Drivers must provide a photo ID during the physical qualification examination and disclose their health history accurately.

The original paper Medical Examiner’s Certificate (Form MCSA-5876) serves as proof of medical certification.

CLP/CDL applicants and holders must provide form MCSA-5876 to their State Driver’s Licensing Agency (SDLA) before their current certificate expires.

Drivers Pursuing an Additional DOT Physical Examination or a Second Opinion

Just like any patient seeking a second medical opinion, CMV drivers have the right to seek another DOT exam from a different medical provider if deemed unqualified to operate a CMV.

Remember, drivers are required to disclose an accurate and complete health history on the Medical Examination Report Form, MCSA-5875, and in discussions with the certified ME during any physical qualification examination.

When a CMV driver disagrees with the certified medical examiner’s decision, they can obtain another DOT physical from a different certified medical examiner, however, transparency is crucial during this process. The driver should disclose all relevant information about their prior exam, including health history and any previous test results.

Resolution of Conflict

Question: Does the Federal Motor Carrier Safety Administration (FMCSA) provide official medical verdicts regarding the physical fitness of individual drivers?

Answer: No, the FMCSA does not typically issue such decisions. However, they may intervene to resolve discrepancies in medical evaluations upon request.

The FMCSA Resolution of Medical Conflict stipulates that if there is a disagreement between two Medical Examiners (MEs) regarding a driver’s medical certification, a provision is in place for drivers and motor carriers to request FMCSA’s intervention to resolve the conflicting medical evaluations. This is applicable when either party does not accept the decision of a medical specialist.

As per the requirements outlined in 49 CFR 391.47, the applicant, who can be either the driver or the motor carrier, must submit a report. This report should include the results of all medical tests and the opinion of an impartial medical specialist in the field where the medical conflict originated. The applicant has the option to submit this information via fax or email.

Website: https://www.fmcsa.dot.gov/contact-us

FMCSA uses the collected information, including medical data, to determine the driver’s qualification. Without this provision and its associated requirements for collecting driver medical information, there is a risk that unqualified individuals may be allowed to drive, and conversely, qualified individuals may unjustly be prohibited from driving.

“Status of driver. Once an application is submitted to FMCSA, the driver shall be deemed disqualified until such time as FMCSA decides, or until FMCSA orders otherwise.”

Remember, transparency, accurate disclosure, and adherence to the NRCME regulations are essential for CMV drivers seeking a second opinion or obtaining a new certificate!

In January 2024, FMCSA will be enhancing its comprehensive medical examiner (ME) performance monitoring and auditing program. Part of this program will include an increase in the Agency’s monitoring of MEs for compliance with the Federal Motor Carrier Safety Regulations (FMCSRs). There are 11 regulatory requirements that MEs must comply with as part of their certification with the National Registry. Failure to comply with the following regulatory requirements outlined in the FMCSRs may result in the removal of an ME from the National Registry:

1. Have a valid unexpired medical license listed in the ME’s National Registry account
2. Provide records within 48 hours of request from FMCSA
3. Submit examination results by midnight (local time) of the next calendar day following the examination
4. Report when no examinations are performed during a given month
5. Complete 5-year periodic training no sooner than 4 years and no later than 5 years after the ME’s certification credential was issued
6. Complete 10-year periodic training no sooner than 9 years and no later than 10 years after the ME’s certification credential was issued
7. Pass the 10-year certification test no sooner than 9 years and no later than 10 years after the ME’s certification credential was issued
8. Update information in the ME’s National Registry profile within 30 days of a change
9. Complete assigned training by the date provided by FMCSA
10. Complete training resulting from an audit by the date provided by FMCSA
11. Correct errors received for CLP/CDL applicants/holders (NRII)

In 2024, FMCSA plans to begin taking action to remove MEs for noncompliance with all of these requirements but will start in January 2024 with MEs who have failed to complete the required 10-year periodic training and/or pass the 10-year certification test as the first certified MEs were due to complete these requirements by December 31, 2023.

For MEs who are required but have failed to complete the required 10-year periodic training and/or pass the 10-year certification test by December 31, 2023, a formal Notice of Proposed Removal (NOPR) from the National Registry of Certified Medical Examiners (National Registry) will be issued to them via the professional contact email address provided in their National Registry account. The NOPR will outline the reason for removal and provide specific details of correction action(s) that the ME must take to avoid removal from the National Registry. FMCSA stresses the importance of thoroughly reading and completing ALL required corrective actions to avoid removal.

After an NOPR has been issued, the ME will see a notification in their National Registry account that prompts them to take the following actions:

1. Acknowledge, through the ME’s National Registry account, that they will take the corrective action(s) outlined in the NOPR or that they disagree with the NOPR. If the ME believes FMCSA has relied on an erroneous reason, in whole or in part, in proposing their removal from the National Registry, the ME can select the option to disagree with the NOPR but must explain the basis for their belief that FMCSA relied on an erroneous reason in proposing their removal for FMCSA to review and respond.

PLEASE NOTE that if the ME has not acknowledged that they will take corrective action(s) in their National Registry account as instructed in the NOPR, the ME will be removed 30 days from the date the NOPR was issued. If the ME acknowledges that they will take the corrective action(s) through the ME’s National Registry account, the ME will have 60 days from the date the NOPR was issued to take corrective action(s) as specified in the NOPR. An example of what the acknowledgement notification in the ME’s National Registry account may look like is provided below.

2. Once the ME acknowledges that they will take the corrective action(s) outlined in the NOPR, they must complete all corrective actions (e.g., completing, entering details, and uploading proof of completion of the 10-year training into the ME’s National Registry account and/or passing the 10-year certification test).

3. Once all corrective actions have been completed, the ME must log into their National Registry account where they will see a notification that they must respond to indicating that all corrective actions have been completed. An example of what the notification may look like is provided below.

PLEASE NOTE that this confirmation is a regulatory requirement and is outlined in the NOPR. MEs who fail to indicate completion of all corrective actions in their National Registry account as indicated in this step, will be removed from the National Registry and will no longer be authorized to perform physical qualification examinations of interstate commercial motor vehicle drivers at the end of the 60 days.

If you receive an NOPR for failure to complete the required 10-year periodic training and/or pass the 10-year certification test by December 31, 2023, you should immediately take the steps outlined in this email and provided in the NOPR, to correct the issue(s) and avoid removal from the National Registry.

To assist MEs in understanding the 11 regulatory requirements listed above that must be met for continued listing on the National Registry, FMCSA will be posting an informational training webinar on the National Registry website in the coming months. MEs will be notified by email when it is available.

To maintain your certification as a Medical Examiner listed on the National Registry of Certified Medical Examiners, you are required to participate in periodic training offered by FMCSA no sooner than 4 years and no later than 5 years after the date of your certification by FMCSA. However, FMCSA acknowledges that there have been delays in releasing the training to Medical Examiners. Due to these delays, FMCSA previously notified MEs that the Agency will not take action against affected MEs for noncompliance with the regulations for not completing the training within the five-year time frame and would provide adequate time for the training to be completed once released. The periodic training is now being made available to all certified MEs that are either currently due or past due.

The periodic training is available through your National Registry account and must be completed by no later than December 31, 2022. Please log into your National Registry account and select Periodic Training Due from the menu options to access the periodic training. Once on the periodic training screen, follow the instructions to download, complete, and certify that you have completed the periodic training. To receive credit for completion of the periodic training, you must print the certification of completion, enter you name, sign and date, scan and save a copy on your computer for upload to your National Registry account. You must then return to your National Registry account, select the periodic training menu item, upload your certificate of completion, and click “Certify Completion of Periodic Training.” Please be sure to retain a copy of your certificate of completion for your records. If you fail to complete the periodic training as scheduled, you will no longer be certified to perform physical qualification examinations of CMV drivers, and you will no longer be listed as examiner certified Medical Examiner on the National Registry.

Please contact the National Registry Technical Support Help Desk at This email address is being protected from spambots. You need JavaScript enabled to view it. or (617) 494-3003 if you have questions regarding the periodic training.

How do medical examiners reach the DOT Medical Examiner Login Screen?

To reach the DOT Medical Examiner Login Screen follow this link:

DOT Medical Examiner Login Screen

Truck driver fatigue is a leading cause of crashes with as much as 13 percent of commercial truck drivers fatigued at the time of a crash, according to the Federal Motor Carrier Safety Administration (FMCSA).