The Value of a Medical Review Officer
When an
individual is prescribed medications by their physician, they are often afraid
that this will cause them to fail a workplace drug test. However legitimately
prescribed medications that are properly taken according to the pharmaceutical
instructions may be verified by a Medical Review Officer (MRO) and will not
count against the individual who is the subject of the drug test.
The cut-off levels also help an MRO determine whether or not an individual has over-consumed a prescribed medication and what steps to be taken following that determination.
The Medical Review Officer is an integral part of the DOT drug testing program, referred to as the “gatekeeper” of the integrity of the drug test by the Office of Drug and Alcohol Policy Compliance (ODAPC). The MRO is responsible for receiving laboratory drug test results, reviewing the results for accuracy, and then evaluating to make certain there are valid medical explanations for the presence of certain metabolites that could be legitimately prescribed medications.
Under DOT protocols, once a laboratory drug test is confirmed positive, the results are sent to the MRO. An MRO must be a licensed physician who has been trained and certified to participate in the drug test resulting process for safety-sensitive employees participating in the transportation industry.
Any metabolites that cannot be verified by a legitimate medical prescription are determined to be illicit drug use and reported out to the employer as a positive.
Occasionally the MRO will see metabolite measurements that are far beyond the cut-off levels and after reviewing the prescribed amounts, it is clear that the consumer may be misusing or abusing their medication. In this case, the MRO may confer with and verify the prescriptive dosage instructions with the prescribing physician.
There are also, instances in which the MRO may recommend a Fit for Duty (FFD) exam in order to determine if the subject of the drug test can perform their duties safely under the influence of prescribed medications. This may occur when the employer is concerned about potentially unsafe behaviors by the donor and required a test under reasonable suspicion circumstances or when the MRO recognizes there may be over-prescribed medications causing complications for the donor and their ability to operate safely.
Employers
may not stand-down an employee or remove them from their safety-sensitive
duties until the MRO has conducted their interview and issued a verified
positive drug test result.
While DOT
employers are required to utilize MROs for their drug testing program and
should cooperate with every part of this process, it is also highly recommended
that non-DOT employers follow the same protocols for absolute best outcomes.
There are several reasons the use of an MRO is wise.
If a
non-DOT employer chooses to receive laboratory drug test results and attempts
to discern the use of prescription medications on their own, they are most
likely in serious violation of HIPPA protections regarding an employee’s
healthcare. It is a risk and a liability to attempt to understand the forensic
cut-off levels of the drug metabolites, to determine next steps in approaching
the employee and to make a decision regarding the outcome of their employment status
without an MRO. Remember the MRO is
responsible for interviewing the employee and discussing medications which
removes that potential conflict from the employer and or their HR Manager and
keeps medical information protected.
MROs may
also testify in court cases where the drug test results become part of the
hearing. This is referred to as expert testimony and is a valuable service if
an employee chooses to challenge an employment decision based on drug test
results.
If for any
reason you have not utilized a Medical Review Officer to verify your company’s
drug test program outcomes, Accredited Drug Testing can help you remedy this
situation so that you are following best practices. Contact us today!