services > occupational healthcare solutions > medical review officer (MRO)

Matching and Inspecting the Documents

On receipt of a positive drug test result from the laboratory, the MRO support staff immediately begins the process of matching the various documents that relate to the subject test result. A review of the Custody and Control Forms is conducted; the forms are assessed for accuracy and completeness. If problems are noted, a determination is made whether to seek an affidavit of correction from the collection provider. If the Custody and Control form is complete and accurate, or has been made complete and accurate by affidavit, the MRO support staff will then initiate the MRO Verification Documentation form. The MRO support staff will complete the form up to the point of MRO Contact. At this juncture, the form, along with the supporting documents (lab results and Custody and Control Form documents), will be given to the MRO.

MRO Review of Documents

Upon receipt of the test result paperwork, the MRO will conduct a second review of the Custody and Control form to ensure accuracy and completeness. The certifying MRO's signature is required on all non-negative test Custody and Control forms.

Initial Attempts at Donor Contact

Following this review, the MRO will attempt an initial contact with the specimen donor. If contact is not made, a second attempt will be made later in the day or that evening. (U.S. DOT regulations require that the MRO make a reasonable attempt to reach the test donor.) If, after 24 hours, the MRO is unsuccessful in reaching the donor, the MRO then contacts an authorized employer representative. During the program implementation process, EBI will work with the client to determine the agreed-upon procedure for attempted donor contacts, which will determine the number of attempts and timeframe.

The MRO Interview

When the test donor is contacted, the MRO will identify himself and make a positive identification of the donor. Following this, the MRO will advise the donor as to the nature of the call and, based on the test result, will conduct the interview. If the donor admits to illegal use of drugs or can offer no medical explanation for the presence of drugs, the MRO will then tell the donor that a verified positive result will be reported to the employer. If the donor cannot present a valid medical explanation for an adulterated or substituted specimen finding, the result will be reported as a Refusal to Test.

Verification of Positive Drug Test

If, during the MRO interview process, the positive test donor states that he was taking prescription medications at the time of the test, the MRO will request information and documentation about the medications, and will request that the donor provide the name, address and phone number of the physician who prescribed the medications to help verify the existence of "Legal Use." The MRO will validate the prescription with the treating physician and/or the pharmacy that filled the prescription. If documentation of authorized medical use is received, the MRO will then report the test result as a negative.

In the case of an opiate-positive result, the burden of proof is on the MRO to determine unauthorized use of an opiate. Unless a special analysis detects 6AM (a metabolite unique to heroin) or the morphine/codeine level exceeds 15,000 ng/ml, the MRO must have "independent clinical evidence" of unauthorized use of opiates in addition to the positive test in order to report an opiate-positive result. The clinical evidence may come from the history obtained during the MRO interview (such as an admission of using someone else's opiate prescription) or from a physical examination (such as the observation of track marks).

Verification of Adulterated and Substituted Specimens

The MRO has a duty to interview a donor whose specimen is found to be adulterated or substituted. If the donor presents documented medical evidence of a condition or procedure that caused the urine specimen to have the physical and/or chemical appearance of an adulterated or substituted specimen, the MRO will report the test as cancelled. Currently there are no known medical conditions or medications that would cause a specimen to naturally meet this criteria.