When a company creates their safety program under the United States Department of Transportation (DOT) regulations one vital spot to fill is that of the Medical Review Officer (MRO). While the Designated Employer Representative (DER) receives test results from the drug and alcohol testing agency and enforces whatever actions are necessary according to the company's drug and alcohol policy, he or she relies on the MRO's medical expertise.
The MRO used by the company as its medical expert must be a licensed physician (Doctor of Medicine or Osteopathy) in the United States, Canada or Mexico. MROs can perform their duties for employers outside of their licensing state or province. The MRO can be an employee of the company or belong to an agency hired by the employer, but the MRO must not have an affiliation with the testing laboratory nor be a part of the process for choosing a testing lab or service.
The MRO acts as an independent and impartial assurer of the accuracy and integrity of the drug testing process. MROs provide a quality assurance review of the drug testing process for the specimens under their authority. They are also responsible to ensure the timely flow of test results and other information from the testing service to the employer, and they protect the confidentiality of the drug testing information.
While MROs are responsible for reviewing the Federal Drug Testing Custody and Control Form (CCF) to determine whether there is a problem that would cause the test to be cancelled, they are not responsible for the internal chain of custody at the testing laboratory.
If lab results show a confirmed positive, adulterated, substituted, or invalid result, the MRO determines whether there is a legitimate medical cause for these results. One such medical cause might be a legally prescribed medication. MROs investigate, as needed, and may be involved in correcting problems and notifying the appropriate parties when assistance is needed. For example, MROs may determine when tests with questionable results must be repeated, if cutoff rates for certain substances are too high, or if the testing facility is not handling specimens according to protocol. The role of the MRO is, in part, to provide feedback to employers, collection sites, and laboratories, regarding performance issues. All this must be in compliance with DOT regulations, especially 49 CFR Part 40.
In the effort to combat substance abuse in the workplace accuracy and integrity are paramount. The highest medical standards must be maintained.The MRO is the key to making this happen.