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Mariner Medical Certification System MERPAC Task Statement #53

Mariner Medical Certification System MERPAC Task Statement #53. CAPT Arthur J. French MD April 3, 2006. Need For Change. Staten Island Ferry ANDREW J. BARBERI allision identified numerous deficiencies in CG Merchant Mariner Medical Certification Process

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Mariner Medical Certification System MERPAC Task Statement #53

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  1. Mariner Medical Certification System MERPAC Task Statement #53 CAPT Arthur J. French MD April 3, 2006

  2. Need For Change • Staten Island Ferry ANDREW J. BARBERI allision identified numerous deficiencies in CG Merchant Mariner Medical Certification Process • These deficiencies existed prior to casualty

  3. Deficiencies Identified By NTSB • Little medical oversight • Inconsistent evaluations and interpretations between examiners • Need for better medical guidance • Interim medical changes not reported • Medical data not stored or tracked • Processing delays/limited CG resources

  4. Challenges • MLD is an extremely complex program defined by numerous statutes, regulations, & international agreements (STCW, ILO) • NMC Restructuring/Centralization • Medical certification is a subjective balance of risk management-public safety versus resources • MLD medical certification is a part of public health policy

  5. MMC Medical Certification System Development Goals • Maritime safety versus standards of care • NMC is not the mariner’s Primary Care Manager • Identify medical conditions requiring waivers • Communicate to mariners via NVIC • Centralized waiver review for quality improvement and standardization • REC waiver authority limited to vision & hearing • Consistency • Expedited processing

  6. Project Objectives • Develop risk-based medical standards • Provide specific guidance on medical certification process to mariners, employers, and examiners through update of NVIC 2-98 • Establish MMLD medical tracking module • Improve consistency of MLD medical certification process through QSS • Develop process for reporting and tracking interim changes in medical status • Requires new regulations • Define NMC Medical staffing requirements

  7. Project Process • MERPAC Task Statement #53 - stakeholder maritime medical subject matter specialists • Leverage medical certification processes of Federal transportation mode partners • Federal Aviation Administration • Federal Motor Carrier Safety Administration • Military Sealift Command

  8. Project Milestones • NVIC 2-98 revision • In concurrent clearance • Publish in Federal Register - May 2006 • MERPAC April 2006 meeting • Occupational risk stratification • MMLD revision - Spring 2006 roll-out • QSS Work Instructions - April 2006 • Augmented medical review staff - 2006 • Medical Advisory Council - 2006/2007

  9. Future NMC Medical Branch • Senior Medical Officer- Branch Chief • PHS officer • GS medical reviewers (2) • Contract medical reviewers (2) • Contract administrative technicians (2) • Assembly line physical review process • Medical Branch will review all CG-719Ks

  10. What Does NVIC Change? • Does not change regulations defining medical standards • NVIC better defines medical conditions and waiver request guidelines • Specifies what needs to be submitted • Includes medications requiring waiver • Limits REC/OCMI waiver authority to vision and hearing waivers only

  11. NVIC Terminology • Disqualifying vs. potentially disqualifying conditions • Waivers vs. “Special Issuances” • “Waiver” used in regulations language • Used by other Federal transportation modes • Need to identify and track mariners with certain medical conditions • Current language is risk management compromise for not making all conditions disqualifying

  12. Desired NVIC Results • Provides better medical guidance (standards) for mariners, RECs, physicians • Helps to ensure consistent interpretations and evaluations between medical examiners • Decreases “additional information” loop which shortens processing time

  13. NMC Waiver Workflow • ?% of waiver requests returned to RECs for additional information • ?% of waiver requests forwarded for physician review • ?% of waiver requests denied

  14. Waiver Processing Times • Avg. Processing Time for Waivers requesting additional information – 30 days • Avg. Processing Time for Waivers reviewed by Doctor – 26 days • Avg. Processing Time for a normal waiver – 12 days *Times were calculated from Jan. ’05 – Mar. ’06

  15. Summary • MLD medical certification is a system of numerous related components • Process efficiency and quality depends upon all system components working • Weakest link in the chain • The NVIC is the “keel” of this ship! • Other parts also need and will be added as program is centralized

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