Recently I wrote “Top 10 reasons seniors are suspicious” of the Liberal government’s driver fitness testing program. Here is the response from the Office of the Superintendent of Motor Vehicles (OSMV). I have made notes on each response, indented, and identified by [X].
Dear MLA Simons,
March 7, 2012
RE: DriveABLE information
As you may be aware, the Office of the Superintendent of Motor Vehicles (OSMV) recently released two new videos about the DriveABLE cognitive assessment process. The two videos can be accessed from the OSMV website or via www.youtube.com/playlist?list=PL97E8B7FE98DF9482. It is hoped the videos will help to better educate and inform OSMV clients, their advocates and relatives and the public about the DriveABLE cognitive assessment process.
The OSMV recognizes that the loss of driving privileges can be a very stressful and upsetting process, and has a significant impact on the mobility and independence of an individual, their family, and friends.
While we realize that any system or process that is used to measure, review and revoke driving privileges will be criticized, even when it’s in the best interests of public safety, we do take all concerns and complaints very seriously. Please be assured that the decision to remove a person’s driving privileges is not taken lightly and in all driver medical fitness decisions the Superintendent strives to balance fairness and an individual’s mobility with the responsibility to ensure public safety for all road users.
Please also find below some corrections, further information and facts in response to public statements made by your office in the “Top 10 reasons seniors are suspicious” published on the www.nicholassimons.ca/ website on February 06, 2012.
Top 10 reasons seniors are suspicious and wary of government’s policy that appears to be resulting in many people losing their license to drive.
1. Seniors are told in writing that they may be dangerous due to cognitive deficits; that they must report for testing; and that they should bring an escort in case they fail.
Drivers of any age can suffer a cognitive impairment and be referred for a DriveABLE assessment, not just seniors. About 95% of drivers referred to the OSMV for a DriveABLE assessment have been referred by medical practitioners who have already conducted a medical assessment and have concerns about their patients cognitive functioning [1]. In many cases the physician has already discussed the issue with their patient and confirmed that the OSMV will be in touch [2]. In the interest of public safety for the driver and all road users, we recommend drivers have someone drive them to and from the assessment [3].
[1] Some of the Medical practitioners (doctors) have referred their patients unwittingly, by administering the newly-mandated SIMARD-MD pre-screening test (Screening Tool for the Identification of Cognitively Impaired Medically At-Risk Drivers. A Modification of the Dem Tect). According to the only study available on the test, the SIMARD-MD which is included in the government’s policy since 2010, may result in a disproportionate number of seniors being sent for further assessment. Here’s a link to the article: http://journals.sfu.ca/cgj/index.php/cgj/article/view/12/38 .
[2] I have heard too many stories where the senior is not even being diagnosed or treated for any issues related to dementia.
[3] Is this because it’s so far away? Is this because the SIMARD-MD has indicated an already serious cognitive decline? No, it’s because if the senior fails the computer test, s/he doesn’t even get to try the on-road portion. Their license WILL be revoked, technically as fast as the OSMV can inform them.
2. Seniors have to spend a lot of money, long hours, and travel long distances to undergo their tests.
Of the 3.1 million drivers in B.C., almost half a million are over 65, but only about 1,500 need to take a DriveABLE assessment each year. The OSMV pays the DriveABLE assessment fees for all the drivers it refers. There are now 17 DriveABLE locations across British Columbia and two locations with mobile services. We continue to look at opportunities for new and existing service providers to deliver mobile services, where required [4].
[4] Still requires seniors to travel high-mountain passes, long trips on ferries, motel costs, re-testing costs $350 ($175 for each portion). Some new offices only offer the computer portion.
3. The test is unfair to people who have literacy challenges, language problems, learning disabilities or arthritis in their hands.
All DriveABLE assessments are administered by a trained healthcare professional [5], who guides the individual throughout the entire assessment providing assistance to ensure the individual understands and can perform all the tasks required in the assessment. Assessors are trained to pick up on the type of physical issues that would interfere with the assessment. In those cases, the OSMV would be informed and other options would be considered.
[5] Not physicians.
[6] Seniors have told me the touch-screen didn’t work, it was too dark, they had no time to practice –even to reduce anxiety.
[7] Has this ever happened, and what options exist?
4. The in-office DriveAble test is unfair for people who have never used a computer or played a video game.
DriveABLE is not a computerized driving test or driving simulator. DriveABLE is an in-office cognitive assessment presented on a touch screen monitor and requires only the touch of the screen or press of a button. There is no mouse or keyboard. Computer knowledge is not required and has no bearing on assessment results. Results are judged against someone without a cognitive impairment of the same age.
[8] Even DriveAble calls it the “computer” portion of the test.
[9] Actually, the button is a stationary mouse.
[10] Show the evidence. It doesn’t exist.
5. The on-road test takes place on unfamiliar roads in an unfamiliar vehicle.
The DriveABLE on-road evaluation is designed on a special road course that reveals driving errors associated with cognitive decline. This evaluation is a secondary cognitive assessment only used when individuals score neither a clear pass nor a clear fail on the in-office assessment [11]. There are potential safety risks for both the driver and the driving examiner as the driver, at this point, has already been identified by their physician and through the in-office assessment as having a possible cognitive issue [12]. This is why the assessment is conducted in a dual-brake vehicle and not the driver’s own vehicle. The DriveABLE evaluator needs to be able to take control of the vehicle. In one jurisdiction, DriveABLE was adopted because of a severe crash that occurred during an evaluation where the driving evaluator was severely injured [13].
[11] Yes, the vast majority of subjects.
[12] That was the potentially biased SIMARD-MD test. If it was so definitive, how could you allow them even to drive over the Kootenay Pass from Cranbrook to Nelson?
[13] What is the statistical likelihood of such a tragic incident recurring?
6. Seniors have to pay $350 to be re-tested if they fail the first time.
DriveABLE is the only evidence-based assessment tool that scientifically examines the cognitive functions essential for safe driving. The OSMV pays the DriveABLE assessment fees for all the drivers it refers. Drivers who fail the DriveABLE assessment and have their license revoked may apply to retake the assessment, although it should be noted that drivers cannot learn to pass the DriveABLE assessment [14]. For drivers who wish to be re-assessed, they are responsible for the fee which is $185 for the in-office assessment or $170 for the on-road assessment, depending on which assessment they may need [15]. The Superintendents’ office will always consider new medical information– e.g. improvement in medical condition, changes to prescription medications, additional physician advice in reviewing a driver’s medical fitness [16].
[14] We know of seniors who have been re-tested, and had their licenses returned.
[15] ICBC tests, where the majority of seniors are referred, allow three tries, with no additional fees.
[16] We will have to test this; so far I have seen no evidence of this. I have a letter from a doctor asking for this, but have not heard a reply.
7. According to a review in the Canadian Geriatrics Journal, the SIMARD MD test used by doctors to screen patients may identify too many drivers requiring DriveAble assessment.
Physicians are free to use other, more general, cognitive and medical screening tools, however SIMARD MD is the screening tool recommended by the OSMV, because it specifically screens those functions necessary for safe driving [17]. To date the SIMARD MD is the only scientifically developed and peer reviewed cognitive screening tool that assesses the cognitive functions necessary for safe driving [18]. The SIMARD MD actually reduces the number of drivers who need to be sent to DriveABLE for evaluation by screening out both very low-risk and very high-risk drivers [19].
[17] Then why does the 2010 Guide say: “Until use of the SIMARD-MD has been fully implemented, the OSMV will accept the MMSE or MoCA as cognitive screens for making driver fitness determinations”?(2010 BC Guide in Determining Fitness to Drive, July 2010).”
[18] Show the evidence.
[19] This is not accurate.
8. The SIMARD MD tool was developed by the spouse of the DriveAble founder and Chief Scientific Officer and has not been peer reviewed.
SIMARD MD is peer reviewed, for more information on the scientific credentials go to: http://www.mard.ualberta.ca/Home/SIMARD/background.cfm#ARTICLE [20]. The tool aims to make a very difficult job easier by allowing physicians to make evidenced based decisions to identify cognitively impaired drivers whose driving skills may be unsafe.
[20] This is SIMARD-MD’s own website.
9. The chief researcher for the government’s “BC 2010 Guide in Determining Fitness to Drive” is the co-creator of SIMARD MD and the spouse of the DriveAble founder.
Dr. Bonnie Dobbs was selected by the US National Highway Traffic Safety Administration (NHTSA) to conduct a scientific review that was published in 2002. That review served as the scientific basis for the NHTSA’s medical guidelines, and later served as the scientific basis of the American Medical Association’s Guide to assessing the older driver. Dr. Bonnie Dobbs was selected by the OSMV to update and extend her scientific review, which was used to help develop the B.C. Guidelines. It is inappropriate to suggest there is any conflict of interest at the University of Alberta between two internationally respected scientific researchers, just because they have a personal relationship and both work and make contributions to this field
[21] Bonnie Dobbs, while respected in her area of expertise, was but one of 86 members of an advisory panel for the NHTSA. Interestingly, the short section on Dementia for which she may have had some responsibility, clearly states that “the determining factor in withdrawing driving privileges should be the individual’s driving ability.” Her literature review of 2002 did not form the scientific basis for the AMA’s Guide.
[22] Fact: Bonnie Dobbs was the principal researcher for the new 2010 guidelines which, for the first time, required the SIMARD-MD which she co-developed, and for the first time (and only time in North America or any Commonwealth Country) required the use of DriveAble assessments, a company founded by her husband.
10. Policy that may result in life-altering decisions should be fair, and be seen to be fair.
Previously, the Superintendent often had to make licensing decisions based only upon the diagnosed presence of a cognitive medical condition. With DriveABLE, the Superintendent reviews a physician’s medical assessment and then provides an opportunity for drivers to individually demonstrate their cognitive medical fitness to continue to drive. The DriveABLE assessment provides a standardized, independent, scientifically validated assessment, removing the potential for bias, and so is currently the most fair and accurate way to make these types of difficult decisions. The in-office tasks are presented using a computer monitor for accuracy, standardization, and so that the administration and scoring are unbiased [23]. The performance of drivers is compared to cognitively competent drivers of their own age [24]. British Columbians expect government to ensure there is a system in place to ensure safe roads for all road users, and DriveABLE is a useful tool for achieving safe roads [25]. Without DriveABLE, the OSMV would have to make licensing decisions based on a more generalized diagnosis and more drivers would have their driving privileges removed.
[23] Actually, this is a huge cop-out. There is no scientific evidence to say this test is accurate or valid. It may catch bad drivers, but it catches many good ones too. It is a blunt instrument at best. The most comprehensive review of such studies concludes assessing drivers in clinical settings has not been prospectively demonstrated. See The Cochrane Library, 2011, Issue 10, http://summaries.cochrane.org/CD006222/driving-assessment-for-maintaining-mobility-and-safety-in-drivers-with-dementia].
[24] Where is the evidence?
[25] Collision rates for senior drivers are lower than for other age groups. The rate of their injury or deaths may be high due to their age/fragility, not frequency of dangerous collisions.
[26] This is simplistic fear-mongering.
The Office of the Superintendent of Motor Vehicles
Ministry of Justice
