THE MRO performs FOUR FUNCTIONS:
RECEIVE lab reports from the laboratory (as governed by regulations)
REVIEW lab reports for integrity, authenticity, false negatives, and false positives.
INTERPRET lab results, including verification of lab positives REPORT lab reports to employers (as defined by rules and regulations
THIS SECTION DEALS WITH THE “REPORTING” FUNCTION
ONTENT OF REPORTS
LAB REPORTS FROM MRO TO EMPLOYER MUST INCLUDE:
- That the controlled substances test being reported was in accordance with 49-CFR-part 40
- The name of the individual for whom the test results are being reported.
- The type of test indicated on the custody and control form (i.e. random, post-accident, etc.)
- The date and location of the test collection.
- The identities of the persons or entities performing the collection, analysis of the specimen and serving as the MRO for the specific test.
- The verified results of each controlled substances test, either positive or negative, and if positive, the identity of the controlled substance(s) for which the test was verified positive….[wherein the term “verified” means that the MRO has verified that the test truly indicates unauthorized use of the substances, using procedures defined in 49-CFR- part 40.]
- If any Quantitative results are given in the laboratory report, employer is not authorized to receive such quantitative results and they should not be transmitted by the MRO to the employer! (Except in the case of contested results or litigation etc.)
FORMAL VERIFICATION OF TEST RESULTS:
- Documentation of Verification is required for BOTH NEGATIVE AND POSITIVE results:
- MRO MUST SIGN verification statement at bottom of CCF form on ALL VERIFIED POSITIVES!
- MRO or MRO-trained delegated staff must sign MRO verification statement on CCF on all NEGATIVES!
MECHANICS OF MRO’s REPORT TO THE EMPLOYER
- Reporting mechanics and requirements are fairly uniform in all Federally regulated programs… but
- In “unregulated” testing, requirements can vary considerably.
- It’s important to understand what rules govern each employer and abide by them.
REGULATIONS: §382.407 Medical review officer notifications to the employer
(a) The medical review officer may report to the employer using any [confidential] communications device, but in all instances a signed, written notification must be forwarded within three business days of completion of the medical review officer’s review. GUIDANCE: (Federal Guidance is regulatory “interpretation” and has the same imperative as a “regulation.”)
- The initial report to an employer may be by telephone.
- All reports, and their transmissions and storage means, must be strictly confidential!
- In every case, a signed written report must be forwarded within 3 business days of completing review.
- Electronic Signatures are specifically not approved by DOT.