Medical Review Officer

A review of results of any drug test is an important factor of all drug testing programs. A laboratory result deemed substituted, invalid or adulterated does not automatically mean tampered specimens, nor does a positive drug test result does not necessarily mean that the person is an illicit drug user. To make a detailed interpretation of possible alternative medical explanations of drug test results, the Department of Health and Human Services (HHS) calls for the expertise of a Medical Review Officer (MRO) for this purpose.

Every credible drug test laboratory needs the services of a Medical Review Officer to provide an expert and independent analysis of positive drug test results confidentially. In the event that the result is positive, the MRO determines if the result is indicative of drug test laboratory in violation of the rules of a working place, or if there is another acceptable explanation for the positive result.

Qualifications of a Medical Review Officer

Based on the HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs, an MRO must be a licensed physician with a degree of Doctor of Medicine or Doctor of Osteopathy. He must have:

  • Expert knowledge regarding the toxicology and pharmacology of illicit drugs and substances.
  • Professional training in the:
    • HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs
    • Procedures in collecting Federal agency specimens
    • Chain of custody including reporting, and record keeping protocols for specimens
    • Proper procedures for the review, interpretation, and reporting of results as identified by the Federal bureau or agency served by the MRO.
  • Passed the examination conducted by an HHS-approved agency such as a sub specialty board for physicians pertaining to the review of Federal employee drug results, or a certifying body for MROs.

Restrictions for Medical Review Officer

The Medical Review Officer may be an independent contractor or an employee of a Federal agency. He or she is the point of contact between the test facility, the donor, the collector and the agency’s representative.  The MRO cannot be:

  • An agent or an employee or anyone with any financial interest in any laboratory or instrumented initial test facility (IITF) where the MRO is reviewing the results of drug tests.
  • In agreement with any laboratory or IITF that could be understood as conflict of interest, or receive any financial gain by recommending the use of a particular testing facility.

These conditions are set to prevent any possible agreement between a drug testing facility and a Medical Review Officer that could influence partiality in reviewing drug test results.

Responsibilities of a Medical Review Officer

In general, an MRO has the following duties and responsibilities.

  • An MRO reviews all specimens that have been reported as positive, substituted, adulterated, rejected or invalid for testing. He is then tasked to report the confirmed or verified result to the state agency.
  • He must ensure that all specimens reported as negative/dilute, or negative are reviewed properly and reported to the state agency.
  • Review the results of all state agency blind samples and do the initial investigation into results that are not consistent.
  • Facilitate or conduct the medical assessment of the person who provided the specimen when the collector-in-charge calls for the services of a licensed medical doctor.
  • Determine the accuracy and potential invalid results with the IITF or laboratory, and determine whether further testing is required.
  • Keeps all records and drug test information a secret.

These above-mentioned qualifications, restrictions and responsibilities of an MRO are stipulated under DOT Rule 49 CFR Part 40.

The role of the MRO in the review includes the following:

  • Checks the drug test panel to see if it was used properly
  • Verifies if the sample collection was conducted correctly
  • Contacts employees with positive drug results to check for medical history or use of legally prescribed medications
  • Reports drug test results (whether negative or positive) to the employer

The MRO protects the employer in terms of making decisions revolving around the drug test results. Although a drug test MRO review is not required in private workplaces under the jurisdiction of the DOT, hiring an MRO for a workplace drug testing program is highly recommended.

Employers who wish to hire an MRO may refer to the American Association of Medical Review Officers (AAMRO) or similar medical groups.

What is an MRO Review?

An MRO review includes the following procedure to guarantee accurate and impartial results:

  • Check if the exact drug test panels were utilized and properly administered
  • Evaluate the handling of the sample collection
  • In case of a negative drug test, review the Chain of Custody Form copy 2 to establish any correctable or fatal errors that may entail to correct or cancel the test
  • In cases of positive drug test results, give the person a chance to explain the presence of such drugs in his system. If the presence of drug is legitimate due to medical prescription, the test is deemed negative.
  • Report the result of the final drug test to the employer after verifying the employee.

MRO reviews ensure that testing facilities used the correct test panel, that the test was conducted properly, and that the collector followed the correct procedures. A positive drug test calls for the MRO to contact the donor to establish if the presence of an illicit substance is due to a legitimate medical prescription for the treatment of an existing medical condition. The MRO will ask the donor to present a valid prescription or doctor’s verification of his medical treatment in support of the positive drug test result to merit a negative report. In case the employee fails to qualify his positive result, the MRO has no recourse but to report the test as “positive”.

An MRO review ensures that the employer is protected from false claims of employees that their positive results are due to an ongoing medical treatment. An MRO review relieves the employer of dealing with a complicated matter relating to the disclosure or release of an employee’s medical information.

An MRO review is a requirement for all Department of Transportation drug tests. Though not required by law, it is highly recommended to use the services of an MRO to interpret the results and assure the accuracy of drug tests.