A Medical Review Officer (MRO) is a certified and trained physician, who holds a degree in Doctor of Medicine or Doctor of Osteopathy. The MRO receives and analyzes the drug testing results rendered through drug testing programs by employers.
The primary role of the MRO is to determine the existence of a valid medical explanation for the positive result during drug testing. MRO interprets the confirmed results by analyzing the validity of the medical explanation. The MRO also analyzes the abnormal negative test results to explain the adulteration or substitution in the sample.
If a positive result is found on drug testing, the MRO contacts the employee to discuss and determine the valid reason for the result. MRO has the power to revoke the results when there is no valid medical reason for a positive result.
Table of Contents
- Who is a Medical Review Officer (MRO)?
- Responsibilities of a Medical Review Officer
- What is a Chain of Custody?
- Chain of Custody Process
- List of MRO Questions after Drug Test
- Do employees or donors need to bring a list of their prescribed medications with them?
- Can a drug test result become positive as a result of passive inhalation?
- What is the average turnaround time for a drug screening?
- Should employers ask their employees for a copy of their prescriptions?
- How many times MRO must attempt to contact the employee regarding a positive test?
- Is it necessary for the MRO to review the employee’s medical history or can any other non-MRO staff member review this information?
- What elements of the CCF do the MRO review before making a final decision on the positive test result?
- To whom does the MRO report the verified positive test result?
- How soon after verification does the MRO convey positive test results to the DER?
- Within how many days must the result be delivered to the employer?
- Can the MRO conclude a drug test result as positive if an employee declines the opportunity to discuss the test results?
Responsibilities of a Medical Review Officer
The MRO works as an employee or contractor for the federal agency. The primary role is to evaluate and determine the positive, negative, adulterated, diluted and substituted drug test results. The MRO has the following responsibilities:
- Identify any problems associated with collecting and testing the samples.
- Guide and assist Fitness for Duty (FFD) testing program management in supervising and planning.
- Examine the medical explanations for test results, conduct a medical interview with the donor, and review the donor’s medical history and biomedical factors.
- Review the entire medical documents and records, i.e., prescribed medication, physiological conditions, disease history which is responsible for the test results.
- To consider the drug test results for specimens and also the split specimens that are collected, stored, processed and tested using the standard procedures.
- MRO is responsible for all technical, professional and administrative activities of individuals who are serving them.
- MRO staff performing the procedures should meet the HHS regulations and standards.
- Donor’s personal information and records should be maintained confidentially, and not released to any entities.
- Data transmission should be done securely.
- Drug test results are reported to the entities only as required.
- MRO staff supports the documentation process like receiving and reviewing the test results, and scheduling interview for the MRO.
What is a Chain of Custody?
Chain of Custody pertains to the maintenance and documentation of the sequential handling during drug testing, which includes custody, control, transport, analysis, and disposal of physical and electronic evidences. These are known as CCF or COC which provides the custody for the collected samples, reduces the tampering by a donor and also serves as a proof for any legal proceedings. It is considered to be the most critical process for documenting the evidence.
As per the standards of DOT, drug testing should be done procedurally, i.e., all the procedures from collecting the sample from the donor, storage of the sample, analyzing, testing, reviewing and reporting the result is documented appropriately. Thus, the CCF should be clear, complete, and precise during documentation for the drug test.
In drug testing, the results of the drug test are kept confidential. Even if the results are positive, it doesn't mean that disciplinary action should be taken on the donor. To ensure integrity throughout the drug testing process, DOT requires the documentation process or paper trail called Chain of Custody Form (CCF).
The specimen collection process and the testing are carried out according to the Substance Abuse and Mental Health Services Administration (SAMHSA) guidelines and standards in drug testing.
Chain of Custody Process
The sample should be collected from the donor safely and securely or under the supervision of the collection facility. The sample collection location should be secured by giving access only to the sample collector and donor.
- The donor’s identity should be verified by their photographic ID to ensure the sample is collected from the authenticated person.
- Then the donor has to fill the details in the chain of custody (COC) form. The donor’s signature with date and approval is required in the form before the sample is collected from him/her.
- Each sample container is sealed securely with unique barcodes placed on them. The COC form should be linked properly with the sample containers to ensure the correct documentation process. Thus, the final results of drug testing will reach the correct donor.
- The facilitator should inspect that no prohibited substances are present in the sample testing areas or the laboratory. In urine drug testing, ensure there is no availability of substances like soaps, cleansing agents, sanitizers or disinfectants. In the case of urine drug testing, even water sources should be made unavailable to the donors in the sample collection room.
- The collection facility supervises the donor throughout the process. In the urine drug testing method, personal belongings such as handbags, jackets, hats, etc., are not allowed in the specimen collection room. The facilitator should check the pockets of the donor for any banned items. The specimen temperature is also checked by the collector to prevent adulteration.
- The facilitator should maintain control over the sample collected and COC form at all times during the procedure. The sample container should be sealed securely and placed in a tamper-proof bag. In the hair follicle testing, the sample should be safely placed in the foil. The documentation work and details should be filled on the tamper-proof bag and it should be signed by the donor.
- Then the tamper-proof bag is securely packed and carried out to the laboratory using a sample carrier. Then the lab-in charge checks for the integrity of the sample and the COC procedure is followed correctly throughout the process of sample collection.
- During sample analysis in the laboratory, the sample container and relevant paper records of the donor are scanned to track the sample to the correct donor, i.e., to the authenticated donor. In this procedure, the donor's confidentiality is maintained by using a unique identification reference number instead of using their name.
- The results are analyzed by the MRO and the medical review is carried out with the donor based on the test results if it is required.
- If the test results are positive, additional testing is required (GC/MS) to confirm the positive results. It takes an average of 24 to 78 hours of turnaround time.
- If the confirmatory test again results positive, the results are forwarded to the MRO officer for review. Then the MRO contacts the donor for confirming whether the positive result is due to any intake of prescription medications. This will take another 72 hours of additional turnaround time. Then the MRO makes the final decision on the results and it is reported to the donor.
- If the confirmatory test result turns negative, the MRO officer reviews the result with the donor and it is reported to them.
- If the test results are negative, the MRO review for the negative result averages a turnaround time of 24 hours. Then the results are reported to the donor.
- The results are reported and all the records are maintained for the documentation purposes, which is required throughout the procedure.
List of MRO Questions after Drug Test
1. Do employees or donors need to bring a list of their prescribed medications with them?
No, it is not necessary for the employees or donors to bring in the medication list for drug testing. The MRO will review with the donor if the prescription information is required.
2. Can a drug test result become positive as a result of passive inhalation?
No, passive inhalation does not produce positive test results in urine specimens. During passive exposure to weed, the presence of carboxy-THC in the urine as well as saliva may be detected if tested immediately after exposure, but it is highly unlikely.
3. What is the average turnaround time for a drug screening?
For a negative drug screen, the turnaround time averages from 24 to 48 hours. For a positive drug screen, confirmatory test such as GC/MS is done to ascertain the positive result. The MRO will then contact the donor to verify if the donor is taking any prescription medications or illicit substances. This process may take around 72 to 96 hours.
4. Should employers ask their employees for a copy of their prescriptions?
No, the MRO will contact the donor to discuss their test result and ask for a copy of the prescription only when there is a valid reason for the positive test result.
5. How many times MRO must attempt to contact the employee regarding a positive test?
The MRO may contact the employee on the same day with the contact numbers mentioned in the CCF form. The MRO may try to contact the employee with a minimum of 3 attempts over 24 hours.
If the MRO is unable to reach the employee, then the date and time of contacting the employee is documented. If the contact numbers mentioned in the form are incorrect, then necessary actions will be taken.
6. Is it necessary for the MRO to review the employee’s medical history or can any other non-MRO staff member review this information?
One of the duties of the MRO is to review the medical history with the employee. No other staff members are designated to perform this. The MRO must conduct a medical interview with the employee and review their medical history and relevant biomedical factors for the non-negative result.
7. What elements of the CCF do the MRO review before making a final decision on the positive test result?
The MRO must review the CCF form to determine if there are any errors present to cancel the test. If the test results are reliable and signed by a certified scientist, the MRO officer need not verify any other documentation of the employee. If the documentation provided by the laboratory is unclear, the MRO officer may request the laboratory to send a legible copy.
8. To whom does the MRO report the verified positive test result?
The MRO must report all the drug test results to the Designated Employer Representative (DER).
9. How soon after verification does the MRO convey positive test results to the DER?
The MRO must transfer or submit the test results such as positive, negative, adulterated or substituted results to the DER on the same day he verifies the result or on the next day.
10. Within how many days must the result be delivered to the employer?
The MRO must hand over the test results to the DER on the same day of verification so that the employer receives the results within two days of verification.
11. Can the MRO conclude a drug test result as positive if an employee declines the opportunity to discuss the test results?
Yes, the MRO officer may verify and conclude the test result as positive if the employee declines to discuss with regards to the test result. The MRO must document the date and time of informing the employee and the employee’s refusal to discuss regarding the test result.