1. Briefing To MEDMAC 5 April 2017
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

2. Topics Medical Evaluation Division (NMC-6)
Regulations: 46 CFR
Guidance: NVIC 04-08
Denial Trends and Recent Rates
Top 5 Reasons for Denials
Questions

3. Medical Regulation 46 CFR 10.301 – Medical Certification
– 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

4. Medical Regulation 10.303 - Medical waivers Limitations Restrictions
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

5. 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

6. 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

7. 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

8. Medical Review Process
Applicants may request reconsideration and appeal for:
Denial of medical certification
Waivers, restrictions and limitations placed on the certificate

9. Denial Trends 2012-2016 808 denials in CY 2012 624 denials in CY 2013
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

10. Denial Rates Compared Pre Division Chief vs. Since Division Chief
July 2015-March 2016
July March 2017
45,787 Applications
244 Denials
7 Appeals overturned
7 Denials Upheld
Denial Rate: .53%
46,492 Applications
84 Denials
No Appeals
Denial Rate: .18%

11. TOP 5 Reasons for Denial
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

12. TOP 5 Reasons for Denial (Cont)
Provider Comments: “Pending Review”, or “Needs assessment from cardiologist” on 719K.
4. Provider marks “Not Fit for Duty” on 719K.
Provider marks “Applicant does NOT have the physical strength, agility, and flexibility to perform all of the item listed in the instruction table.”

13. 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)

14. Back-Up Slide Processing Time Trend