In September of 2018, the Federal Motor Carrier Safety Administration (FMCSA) officially changed its approach towards commercial vehicle operators with insulin-treated diabetes mellitus (ITDM). The final rule went into effect on November 19, 2018.
The final rule replaces the former Diabetes Exemption Program with a new Medical Examiner's Certificate (MEC). Under this new system, a treating clinician (TC) evaluates an individual's diabetes management. Once the evaluation is complete, the TC sends the assessment to the Certified Medical Examiner (CME). If satisfied, the CME may issue a MEC valid for up to 12 months.
Bottom line? No more medical exemptions are necessary!
Prior to this change, the FMCSA held that individuals with insulin-treated diabetes would have to acquire a special FMCSA exemption in order to operate commercial motor vehicles (CMV) involved in interstate commerce.
Exemptions would typically last two years. However, acquiring the medical exemption was not easy -- a lengthy application process was expensive and time-consuming.
The process -- the Diabetes Exemption Program -- could take up to 6 months to process. For many operators, this wait was simply impractical (and expensive).
Why Make Such a Change?
The old system required the following:
• A lengthy processing time (average of 77 days, up to 180 days maximum)
• An annual certification by a Medical Examiner
• An annual vision examination
• An annual examination by an endocrinologist
• Three mandated quarterly visits to an endocrinologist
In contrast, the new system:
• Requires no processing time
• Requires a single annual evaluation by a treating clinician
• Requires a single annual certification issued by a certified Medical Examiner
The FMSCA estimates that the new system will save $6.35 million each year -- a decrease of 79%.
Who Does This New Rule Apply To?
The FMSCA's new rule applies to anyone with insulin-treated diabetes and who operates a CMV involved in interstate commerce.
It's important to note that the definition of "interstate commerce" is fairly open-ended. The following individuals are examples of just some of the people affected by the rule change:
• Truck drivers
• Bus drivers
• Construction vehicle operators
• Delivery vehicle drivers
• Airport shuttle or bus operators
What the Change Means for Individuals with ITDM
The FMSCA has implemented a new Medical Examiner's Certificate in lieu of the previous Diabetes Exemption Program.
For an individual with ITDM and who currently has a diabetes exemption, you will need to obtain a new medical certification.
Obtaining the New Medical Examiner's Certificate
Thankfully for interstate commercial motor vehicle operators, the new system is quite simple and fairly unintrusive. Instead of waiting for up to 6 months to hear back regarding an exemption, a licensed Medical Examiner is able to certify an operator much more quickly.
What's the Process?
The process is fairly simple.
The operator must seek an assessment from their treating clinician. The treating clinician needs only complete the new Insulin-Treated Diabetes Mellitus Assessment Form (MCSA-5870) and provide it to a certified Medical Examiner.
The Medical Examiner then makes a judgment on whether the individual's diabetes is sufficiently managed. If the Medical Examiner approves, he or she may issue a Medical Examiner's Certificate (MCSA-5876). This certification is valid for up to 12 months.
Compared to the old system, the new process is less expensive, considerably faster, and less intrusive.
What Does the Treating Clinician Determine?
The treating clinician determines the following:
• Whether the individual has a stable insulin regimen
• Whether the individual has properly controlled insulin-treated diabetes
What Does the Treating Clinician Need?
In order to determine ITDM stability, treating clinicians typically need three months of blood glucose records. If those records are not available, the treating clinician may issue a temporary assessment. This temporary certificate is valid for up to three months.
This new process allows an individual's physician considerable freedom in determining whether the ITDM is stable.
What About Hypoglycemic Episodes or Diabetic Retinopathy?
However, it's important to note that any severe hypoglycemic episode disqualifies an individual from this process. The FMSCA now:
• Prohibits operators with hypoglycemic episodes from operating commercial motor vehicles until a clinician has evaluated the operator
• Prohibits said operation until the operator and TC address the cause of the hypoglycemic episode
The prohibition from operating a CMV continues until the TC completes an evaluation of the ITDM individual.
For ITDM individuals diagnosed with either severe non-proliferative diabetic retinopathy or proliferative diabetic retinopathy, there is no way to legally operate a CMV involved in interstate commerce.
What About Current Exemption Holders?
Individuals with diabetes exemptions issued by the Diabetes Exemption Program will need to obtain new certifications before their current exemptions expire.
Annual renewal of the Medical Examiner's Certificate is necessary.
New Process, Better Results
The new FMSCA rule on diabetes is a significant step forward for ITDM individuals and the organization as a whole. Lower costs, shorter processing times, and an eased burden are net wins for everyone involved. Feel free to read the exact copy of the FMSCA final rule here.
Form MCSA-5870 Insulin Treated Diabetes Mellitus Assessment Form