NVIC 10-14 and Management of Medical Care

Currently working towards a STCW >3000GT Chief Mates ticket. My sea service towards this endorsement started prior to 3/24/14. I hold a 1600GRT/3000GT Masters in addition to a 2/M Unlimited/OICNW. I have chosen to follow the new NVIC 10-14 assessment regime just in case I can’t get finished before 12/31/16. (I also used my one “raise-in-grade after 3/24/14” on my 1600/3000 Masters, which I think voids the 2019 deal with the old assessments.)

On to the actual question. NVIC 10-14 tasks 19.1.A, 19.2.A, and 19.3.A refer to a required course - Management of Medical Care. These are also “Note 1” assessments not required for holders of a 3000GT Masters (like quite a number of the others). NVIC 10-14 and the NMC STCW checklist for >3000GT Chief Mate state that I can opt to use either assessment regime (04-02 or 10-14), and the new course schedule is a separate check box listed under the heading “If sea service started after 3/24/14”. The issue I see is that the assessments and courses are intertwined in NVIC 10-14.

So, is Management of Medical Care required for me? And under what rule does that answer follow?

To date, I have received 3 conflicting answers from NMC:

  • One “no” it’s not required, since my service started before 3/24/14 (supposedly confirmed by a supervisor). But this implies I can use the 10-14 assessments and not take ANY courses, which seems… odd),
  • One vague “yes” it is required,
  • One ‘since your service was before 3/24/14, you HAVE to use the old assessments’ (which is easily refuted as wrong).

Side note: I’ve already taken all the other new classes except one scheduled next month, and my tasks are otherwise complete. If MoMC was widely available I’d gladly take it, but only Star Center offers it as a stand-alone, and quite rarely at that. The only resort to get it before 12/31/16 (and avoid BT and Adv FF) would be to plunk down $2k + lodging + travel + 10 days of my off time for Med-PIC – an extreme overkill substitution for the 4 hour MoMC.

I would imagine if it says the assessment is not applicable to a holder of Master 3,000 then you don’t have to take the course.

Since when is there only one grandfathered upgrade?

That was my first inclination, but it’s still listed as a required course, so I didn’t want to hang my hat on that. It’s just hard to believe such a large loophole exists, albeit, it appears that the requirements for 3000GT Master will get much tougher for those who started after 3/24/14.

I believe you need to take the Med PIC course. Per the NVIC 10-14, Enclosure (1) para 2.e.:

“In accordance with 46 CFR 11.307(d), mariners holding an STCW endorsement as Chief
Mate of vessels of 500 GT or more and less than 3,000 GT are eligible for the
endorsement as Chief Mate on Vessels of 3,000 GT or More after completing 6 months
of sea service as Chief Mate of Vessels of 500 GT or More and less than 3,000 GT [B]and
any training and/or assessment required for Chief Mate on vessels of 3,000 GT or more
not previously satisfied.[/B] Assessments that must be completed are noted in Enclosure (2).”

Also, I cannot believe there is a 4 hour course that satisfies the “Management of Medical Care” training requirement. You should note also that if the course is a stand alone one (i.e., not combined with “Medical Care Provider”), it can be one week long and the attendee must have completed the MCP course within 6 months of starting the PIC class (ref NVIC 03-14, Encl. (3), page 11).

Perhaps Mr. Cavo can weigh in.

What I read above is if you want to use a C/M 500-3000GT as your sea service (as opposed to OICNW/2M-Unlimited time)and upgrade the tonnage, that’s what you have to do. I’d be doing it with OICNW time (I apologize for not specifying), but I hold a 3000GT Masters which covers some assessments, which brings me to paragraph 2.d. Paragraph 3 is also applicable, it just seems hard to separate the courses from the new assessment regime.

Regarding the course, if you look at the NVIC 10-14 assessments the class covers, it’s a joke. It’s just a fancy course name. The NMC’s approved course search function for MoMC lists only the Star Center, and they have it as a 4-hr course. A shipmate of mine took it a while back. Medical Care Provider and Medical PIC are entirely different classes of different scope, and MCP is actually an operational level course that’s required for OICNW.

Here’s the Star Center course (.pdf) :
https://www.star-center.com/courses/CM-MgmtMedicalCare.pdf

You are right about the courses. I was thinking that the MoMC satisfied more than just the three medical assessments and the 46 CFR training requirement. It does nothing towards getting an STCW endorsement for Med PIC.

[QUOTE=wafinator;190276]…On to the actual question. NVIC 10-14 tasks 19.1.A, 19.2.A, and 19.3.A refer to a required course - Management of Medical Care. These are also “Note 1” assessments not required for holders of a 3000GT Masters (like quite a number of the others). NVIC 10-14 and the NMC STCW checklist for >3000GT Chief Mate state that I can opt to use either assessment regime (04-02 or 10-14), and the new course schedule is a separate check box listed under the heading “If sea service started after 3/24/14”. The issue I see is that the assessments and courses are intertwined in NVIC 10-14.

So, is Management of Medical Care required for me? And under what rule does that answer follow?[/QUOTE]

You don’t need the course until January 1, 2017 if your service started before March 24, 2014. Until then you can qualify under the old regulations (no course required) and using the old assessments. There was no assessment noted for Management of Medical Care under NMC Policy Letter 4-02, the explanation of why is long, I’ll summarize and say the old policy letter only had assessments for practical demonstrations, and NVIC 10-14 notes them for the entire competency table in STCW. The extent that you can use the new assessments under the old rules is addressed in an enclosure to the NVIC.

Medical Care PIC is not the same as Management of Medical Care. No one is required to take Medical PIC to get endorsements for Chief Mate or Master. Management of Medical Care is a single, short (about 4 hours) lesson in a much longer PIC course. Taking the longer course is not required for Chief Mate/Master, but would meet the requirement as the management topics are included in the longer course. A 4 hour course approved for Management of Medical Care would be acceptable, but there are not likely to be many available at this time as the course has generally not been required for anyone to date, but will be after January 1, 2017. When more people need the course, there will likely be more available.

[QUOTE=Capt. Phoenix;190300]I would imagine if it says the assessment is not applicable to a holder of Master 3,000 then you don’t have to take the course.

Since when is there only one grandfathered upgrade?[/QUOTE]

See above. It’s not a grandfathered course, the same course would meet the new requirements. The reason there is/was only one is that as noted above, no one had to take it, it ws specified in NMC Policy L:etter 4-02, but the course s noted in that policy letter were not in the regulations at the time, and thus were not enforced.

[QUOTE=Decker;190342]I believe you need to take the Med PIC course… [/QUOTE]

No, the Medical PIC course is NOT required to get the Chief Mate or Master endorsement.

[QUOTE=Decker;190342]…Also, I cannot believe there is a 4 hour course that satisfies the “Management of Medical Care” training requirement. [/QUOTE]

Sea above. The new requirement for Chief Mate or Master is for Management of Medical Care, this is not the same as Medical Care PIOC, and a short course would be acceptable (it’s not grandfathering) However, if you only take the short course you are not qualified for Medical Care PIC.

Thanks for the detailed response Mr. Cavo!

So… can I use the 10-14 assessments without the course since it wasn’t required under the old rules (and there’s no equivalent requirement in 04-02)? I guess that is the crux of my dilemma.

I have all the other new required courses and have the 10-14 Tasks completed (except the 19’s for MoMC) taking advantage of the “Note 1” provision with my 1600/3000GT Masters.

[QUOTE=jdcavo;190435]It’s not a grandfathered course, the same course would meet the new requirements.[/QUOTE]

I never said grandfathered course, I said grandfathered UPGRADE. He already upgraded once since March 2014 under the old rules and thinks he can’t upgrade again under the old rules. I see nowhere in the CFR that says you only have one grandfathered upgrade.

Yeah for that I was referring to NVIC 02-14, Enclosure 1, Paragraph d that gives you until 2019, but only under that premise:

A mariner who started approved or accepted training or seagoing service before March 24, 2014, and is applying for his or her first raise of grade or original credential after March 24, 2014, may qualify under the regulations in place before March 24, 2014, provided that application is made before March 24, 2019.

However, everywhere else I’ve looked including the CFRs states 12/31/16 as the deadline to submit the old C/M assessments, without the “first since 3/24/14” stipulation. I’ll do it before 2017 regardless, but I don’t think I can use NVIC 02-14 to go beyond that since I’ve already upgraded once. I was really just trying to answer a question before it was raised in case anyone else knew about that provision. There probably are a number of arguments to be made about its interpretation, but I’m playing it safe.

2017 is the deadline for STCW endorsement changes, 2019 is the deadline for national license changes. Since what you after is your STCW endorsement you have until 2017.

[QUOTE=wafinator;190631]However, everywhere else I’ve looked including the CFRs states 12/31/16 as the deadline to submit the old C/M assessments, without the “first since 3/24/14” stipulation. I’ll do it before 2017 regardless, but I don’t think I can use NVIC 02-14 to go beyond that since I’ve already upgraded once. I was really just trying to answer a question before it was raised in case anyone else knew about that provision. There probably are a number of arguments to be made about its interpretation, but I’m playing it safe.[/QUOTE]

When I took my last remaining CM/M classes this summer at MITAGs, their contact at the NMC said the deadline for using the old CM/M assessments (Policy Letter 04-02) has been extended for 1 year. If you are curious or want confirmation you can email the NMC (don’t call…they may not give you the right answer) and/or talk to the license guy at MITAGs - Victor Tufts - who is a great help to all folks applying to the Coast Guard.