Overview of Denials in Medical Evaluation Division
Dr. Laura Torres-Reyes presents the top 5 reasons for 719K denials by the Medical Evaluation Division. The briefing covers key aspects such as regulations, guidance, medical certifications, waivers, and review processes, including determinations for qualification and denial of medical certificates.
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Top 5 Reasons For 719K Denials by the Medical Evaluation Division Dr Laura Torres-Reyes, M.D., M.P.H., F.A.C.O.E.M. NMC-6 Division Chief Briefing To MEDMAC 5 April 2017
Topics Medical Evaluation Division (NMC-6) Regulations: 46 CFR 10.301 Guidance: NVIC 04-08 Denial Trends and Recent Rates Top 5 Reasons for Denials Questions 2
Medical Regulation 46 CFR 10.301 Medical Certification 10.304 The General Medical Exam No conditions that pose significant risk of sudden incapacitation or debilitating complication Medication that impairs cognitive ability, judgment or reaction time Demonstration of Physical Abilities Vision Requirements (incl. color vision) Hearing Requirements
Medical Regulation 10.303 - Medical waivers Medically unqualified Extenuating circumstances Limitations May limit operations e.g. daylight only, no watch-standing May limit duration of the medical certificate Restrictions May restrict route or trade e.g. near-coastal
Medical Guidance Navigation and Vessel Inspection Circular (NVIC) 04-08 Enclosure (2) - Physical Ability Guidelines Enclosure (3) - Conditions subject to further review May require a waiver May lead to denial of medical certification Recommended evaluation data Encl (4) - Medications that pose risk of impairment May require a waiver May lead to denial of medical certification
Medical Review Process 719K reviewed for Conditions that may pose significant risk; conditions subject to further review Medications Physical Abilities Exam findings Supporting documentation treating provider, test results Examining practitioner s recommendation
Medical Review Process Possible Determinations Physically and medically qualified Qualified with restrictions and/or limitations Requires a medical waiver Additional information needed before a determination can be made Not physically and medically qualified; medical certificate is denied
Medical Review Process Applicants may request reconsideration and appeal for: Denial of medical certification Waivers, restrictions and limitations placed on the certificate
Denial Trends 2012-2016 Number of denials has decreased 808 denials in CY 2012 624 denials in CY 2013 401 denials combined CY 2014 and CY 2015. 179 denials CY 2016 25 denials first 3 months of CY 2017
Denial Rates Compared Pre Division Chief vs. Since Division Chief July 2015-March2016 45,787 Applications 244 Denials 7 Appeals overturned 7 Denials Upheld Denial Rate: .53% July 2016- March 2017 46,492 Applications 84 Denials No Appeals Denial Rate: .18% 10
TOP 5 Reasons for Denial 1. Requested Amplifying Information (AI) not received: 174 for Jul 2015-Mar 2016 40 for Jul 2016-Mar 2017 Eliminated requirement for administrative AI Implemented Division Chief review after 90 days 2. Mariner has condition that poses a high risk of sudden incapacitation: OSA, Seizures, Substance Abuse, CAD, Medications 11
TOP 5 Reasons for Denial (Cont) 3. Provider Comments: Pending Review , or Needs assessment from cardiologist on 719K. 4. Provider marks Not Fit for Duty on 719K. 5. Provider marks Applicant does NOT have the physical strength, agility, and flexibility to perform all of the item listed in the instruction table. 12
Questions? Dr. Laura Torres-Reyes, M.D., M.P.H., F.A.C.O.E.M. Medical Evaluations Division Chief U.S. Coast Guard National Maritime Center 100 Forbes Drive Martinsburg, WV 25404 (304) 433-3552 Laura.A.Torres-Reyes@uscg.mil 13
Back-Up Slide Processing Time Trend 14
