Avoiding the NRCME Trapdoor

Celebration of the chiropractic profession's inclusion into the NRCME program has settled a bit. The balloons are being collected. The champagne corks are being swept up off the floor. We all know the process, the final rule and all of the procedures we must go through in beginning or continuing to perform these vital examinations. Chiropractic physicians, despite some mild opposition, had ardent and unwavering support from the Federal Motor Carrier Safety Administration. This is all good for our profession, which despite itself at times, is gaining integrity and strength in the health care system. NRCME is just the first step.

So, we must ask, "Now, what do we do with the NRCME program?" This is the question no one is talking about. We are joyously jumping up and down and saying, "We are on par and equal with our allopathic counterparts." Well, yes, we are now on the same level as our colleagues in the medical profession. But for how long?

I have been training future NRCME examiners for three years across the country in anticipation of the release of this program. We have been stressing to the chiropractic profession for a long time about how important this program is to our future; how many programs at the federal and state levels will be bolstered by our inclusion in the NRCME. Now the program has been finalized and we get ready to begin our official training.

Training will have to be PACE certified or if your state allows, ACCME certified. These are the only two national certifying organizations that serve our profession. Individual trainers will have to meet the requirement or your training may be denied by the FMCSA. Caution number one.

Some training will combine drug and alcohol testing along with the NRCME-required material. Some will be online. Some will be lecture based. Your state associations may sponsor training. The national associations will likely be sponsoring training. Your choices will be vast and varied. Do you want to travel? Do you want to train at home? Do you want to incorporate drug and alcohol testing, which is the triumvirate requirement of the FMCSA for truck and school-bus drivers? Caution number two.

Competency is the potential trapdoor. Those who take this program lightly are going to more than likely find themselves in a pot of boiling water. There is no doubt our profession is behind the curve slightly in the NRCME learning endeavor. I have spoken to DCs across the country and trained them. Some are well-qualified at the DOT physical task and more thorough than some allopaths in DOT exams. Some have not a clue and do not know the smart end of a stethoscope. They are looking at this as a practice booster.

I caution those examiners who are looking at the NRCME as a way to increase revenue alone. This program will require you to be more than competent in FMCSA rules, regulations, exam procedures and yes, pharmacology.

My training estimates exceed by double the estimated amount of time it will take the uninitiated examiner up to get up to speed on this program. For those who are seasoned examiners in the DC profession, tread lightly and listen, for you will learn many new things. I estimate anywhere between 12 hours online and up to 18 hours in a lecture-based program … and that's not including drug and alcohol training.

So, why is competency so important in the program? Heck, most drivers are young and healthy, and we can just do a cursory exam, get them out the door, collect our $80 in cash and move on, right? True, a lot of these exams are very simple. However, when a complicated driver exam presents itself, the examiner must know how and when to certify these drivers. The examiner must be thorough, confident, accurate and able to communicate well to the driver and the company for which they work.

In the past, examiners have not been observed in their performance of DOT exams. Thus, a broad spectrum of examiner competencies and motivations were in the mix. Some examiners were "rubber stampers" trying to collect a buck. Others were "Atilla the Hun" examiners, applying random, ill-advised restrictions, forcing drivers to "doctor shop" to get certifications. With the new NRCME program, we will be watched – closely. All professions will be observed and data tracked. It will take a few years to get that data, but it will be powerful, objective evidence supporting categories of examiners – or providing fuel for their removal. Does this sound "Medicare-esque?"

Some not just DCs, but all of the examiner categories) will attempt to take advantage of the program. Nicely, the FMCSA will be able to pluck them out of the program and discipline them. This removal will not only be for malfeasance, but also for errors of omission and documentation errors.

I was fortunate to speak in May at the Occupational and Environmental Medical Symposium at the University of California, Davis. Afterward, an MD came up to me and stated how much he admired me coming to the program. He told me that his environmental medicine group had protested the inclusion of DCs, PAs and NPs in the program. However, he and others had realized the resistance was futile.

His parting words were heeded as a warning. He told me that they opposed it from the onset and that he and others will reserve action on our participation until after the data comes out in a few years. He said, "then we can objectively look at who is strong and who is weak in the NRCME program."

I told him it would be sad to see the MD profession eliminated based on its performance. We had a moment of mutual chuckle, but his words rang true.

Embrace this program, chiropractic physicians, for you are truly and undoubtedly physicians in our health care system. Take the role of the NRCME very seriously from the start and avoid the trapdoor.