{"id":50849,"date":"2014-03-23T15:39:45","date_gmt":"2014-03-23T15:39:45","guid":{"rendered":"https:\/\/www.nationaldrugscreening.com\/?p=50849"},"modified":"2023-09-06T10:22:12","modified_gmt":"2023-09-06T15:22:12","slug":"mistakes-people-make-mro","status":"publish","type":"post","link":"https:\/\/www.nationaldrugscreening.com\/blogs\/mistakes-people-make-mro\/","title":{"rendered":"Medical Review Officer (MRO) Mistakes in Drug Testing"},"content":{"rendered":"

Mistakes People Make –\u00a0Medical Review Officer – MRO<\/strong><\/p>\r\n\r\n

This third article on\u00a0Mistakes People Make<\/em>\u00a0will focus on the Medical Review Officer (MRO)<\/a><\/strong> and staff under the direction of the Medical Review Office – the MRO Assistants.\u00a0 The most famous mistake regarding the medical review of drug tests resulted in the issuance of a public interest exclusion (PIE) which is a DOT mechanism designed to protect the public from the affects of serious noncompliance by service agents.\u00a0 The Federal Aviation Administration (FAA) brought this PIE action after investigating and substantiating that a service agent violated Part 40 on many occasions because Mr. Michael Bennett of Workplace Compliance, Inc. in North Carolina, Texas had performed all roles and responsibilities of a Medical Review Officer (MRO) under Part 40, even though he was not a licensed physician (a Doctor of Medicine or Osteopathy), and therefore not qualified to act as an MRO.\u00a0\u00a0 For a period five years, Mr. Bennett and his company are excluded from providing DOT drug testing services.\u00a0 DOT notified employers and the public about this PIE by publishing a “List of Excluded Drug and Alcohol Service Agents” at\u00a0http:\/\/www.dot.gov\/ost\/dapc\/pie.html<\/a>.\u00a0 At the time of the publication of this article, Mr. Michael Bennett of Workplace Compliance, Inc. is the only service agent on this list; view the link above for more recent PIE’s.<\/p>\r\n\r\n

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DOT Public Interest Exclusion (PIE) List<\/strong><\/p>\r\n<\/td>\r\n<\/tr>\r\n

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Name and Address of Service Agent:<\/strong><\/p>\r\n<\/td>\r\n

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Michel R. Bennett and Workplace Compliance, Inc. in North Carolina and Texas and all other places it is incorporated, franchised, or otherwise doing business<\/p>\r\n<\/td>\r\n<\/tr>\r\n

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Other Persons or Organizations:<\/strong><\/p>\r\n<\/td>\r\n

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Officers, employees, directors, shareholders, partners or individuals associated with Workplace Compliance, Inc<\/p>\r\n<\/td>\r\n<\/tr>\r\n

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Scope:<\/strong><\/p>\r\n<\/td>\r\n

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Acting as a service agent or providing any drug and alcohol testing services to any DOT regulated entity.<\/p>\r\n<\/td>\r\n<\/tr>\r\n

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Duration [beginning & end dates]:<\/strong><\/p>\r\n<\/td>\r\n

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July 31, 2009 – July 31, 2014<\/p>\r\n<\/td>\r\n<\/tr>\r\n<\/tbody>\r\n<\/table>\r\n<\/div>\r\n\r\n\r\n\r\n

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Mistakes can be costly, particularly the flagrant mistakes.\u00a0 Mr. Bennett also ended up serving time in prison.\u00a0<\/p>\r\n\r\n\r\n\r\n

Lear more about MRO Services<\/a> from National Drug Screening.<\/p>\r\n\r\n\r\n\r\n

Collector errors resulting in canceled tests require that the collector receive error correction training.\u00a0 Some MRO\u2019s have been known to neglect to notify the collection site of the error and the retraining requirement. Collectors need to be aware of the mistakes they make so as to avoid repeating the same mistake, the MRO must ensure the training takes place.<\/p>\r\n\r\n\r\n\r\n

When a third party administrator (TPA) is involved as the intermediary in the transmission of the MRO\u2019s verified drug test results, this is an employer decision and should be communicated from the employer to the MRO and to the TPA.\u00a0 Often the TPA makes this decision for the employer and no documentation of the employer\u2019s decision is maintained.\u00a0 This is clearly addressed in Part 40 \u2013 40.35, 40.45 and 40.345. An MRO should ensure that the employer has made the decision for the TPA to be involved as the intermediary in the transmission of the MRO\u2019s verified drug test results.<\/p>\r\n\r\n\r\n\r\n

My good friends Sandy Vanderploeg and Doctor Jim Vanderploeg shared with me some mistakes in the MRO process that they have heard about around the industry. Sandra is the instructor for the DATIA MRO Assistant training course and Jim is an MRO. \u00a0Sandra and Jim own and operate a TPA and MRO business – Interactive Medical Connections, Inc in Houston, Texas.\u00a0 Sandra also serves on the DATIA Board of Directors.\u00a0 I have known Jim for over 15 years and have found him to be a highly qualified and knowledgeable Medical Review Officer.<\/p>\r\n\r\n\r\n\r\n

Sandra\u2019s list was a fairly long list as there are quite a few mistakes that can occur; she hears of a lot of them during her MRO Assistant training courses.\u00a0 This is a must have training for any staff under the supervision of an MRO and also highly recommended for MRO\u2019s.\u00a0 Sandra does a great job with this training. \u00a0\u00a0A few of the issues she has heard of are discussed here.<\/p>\r\n\r\n\r\n\r\n

Regarding the signing of negative result reports, the MRO staff may rubber stamp and initial negative results.\u00a0 The stamp should identify the MRO and the initial should indentify the MRO staff member, many of the MRO assistants are stamping the MRO name and placing the MRO initials on the report.<\/p>\r\n\r\n\r\n\r\n

Negative results are often reviewed by the MRO assistant.\u00a0 A negative result that is dilute requires a second look.\u00a0 If the creatinine level is between 2 mg\/dl and 5 mg\/dl and specific gravity less than or equal to 1.0010, the employer should be notified that an immediate second collection under direct observation is required.\u00a0 MRO assistants miss this from time to time.\u00a0 Medical Review Officers (MROs) do not interview these donors, but report the result as a “Negative, dilute, Immediate Observed Re-collection Required”.<\/p>\r\n\r\n\r\n\r\n

A Medical Review Officer determines a refusal to test based on adulteration, substitution or shy bladder and the donor has no medical reason for the shy bladder.\u00a0 MRO\u2019s may make the mistake at times of getting involved in refusal decisions that are the responsibility of the employers Designated Employer Representative (DER).\u00a0 These include refusals based on collection problems such as leaving the collection site, not cooperating with the collector or getting caught with a prosthetic or other device that could be used to interfere with the collection process.<\/p>\r\n\r\n\r\n\r\n

Another mistake that is made at times by MRO\u2019s is strictly following DOT regulations for the medical review of non-DOT testing.\u00a0 This exposes the employer to a liability situation.\u00a0 Some state laws have different provisions for medical review of drug testing and not always consistent with DOT regulations.\u00a0 Iowa and Connecticut have laws requiring the donor to personally receive written notification of a positive test.\u00a0 Waiting to report a non contact positive according to DOT rules (10 days) could violate State Laws, Union agreements or company policies.\u00a0Florida and Arizona laws provide for five days.\u00a0 Several States differ from the DOT rule on the amount of time the donor has to request a split specimen retest.\u00a0 For DOT it is 72 hours; Florida it is up to 180 days, Minnesota up to 3 days, Mississippi and Vermont up to 90 days.\u00a0\u00a0<\/p>\r\n\r\n\r\n\r\n

Avoid all of these issues, do it right the first time \u2013 the key is training and refresher training and keeping up to date with the regulations.\u00a0 There are two great MRO organizations available for MRO\u2019s to keep up to date, receiving training and get guidance. \u00a0 Look also to DATIA, which is now the\u00a0National Drug & Alcohol Screening Association (NDASA)<\/a>, for a great resource for regulatory updates, training and promotion of the highest possible standards for the industry.\u00a0<\/p>\r\n\r\n\r\n\r\n

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Medical Review Officer Organizations<\/strong><\/p>\r\n<\/td>\r\n<\/tr>\r\n

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<\/strong>Medical Review Officer Certification Council (MROCC) –<\/strong> \u00a0https:\/\/www.mrocc.org\/<\/strong><\/a><\/p>\r\n

American Association of Medical Review Officers (AAMRO) –<\/strong>\u00a0http:\/\/www.aamro.com\/<\/a><\/strong><\/p>\r\n

\u00a0<\/strong><\/p>\r\n<\/td>\r\n<\/tr>\r\n<\/tbody>\r\n<\/table>\r\n<\/div>\r\n\r\n\r\n\r\n

 <\/p>\r\n","protected":false},"excerpt":{"rendered":"

Mistakes People Make –\u00a0Medical Review Officer – MRO This third article on\u00a0Mistakes People Make\u00a0will focus on the Medical Review Officer (MRO) and staff under the direction of the Medical Review Office – the MRO Assistants.\u00a0 The most famous mistake regarding the medical review of drug tests resulted in the issuance of a public interest exclusion […]<\/p>\n","protected":false},"author":12,"featured_media":51643,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_seopress_robots_primary_cat":"none","_relevanssi_hide_post":"","_relevanssi_hide_content":"","_relevanssi_pin_for_all":"","_relevanssi_pin_keywords":"","_relevanssi_unpin_keywords":"","_relevanssi_related_keywords":"","_relevanssi_related_include_ids":"","_relevanssi_related_exclude_ids":"","_relevanssi_related_no_append":"","_relevanssi_related_not_related":"","_relevanssi_related_posts":"","_relevanssi_noindex_reason":"","footnotes":""},"categories":[181],"tags":[],"acf":[],"_links":{"self":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50849"}],"collection":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/users\/12"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/comments?post=50849"}],"version-history":[{"count":2,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50849\/revisions"}],"predecessor-version":[{"id":118343,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50849\/revisions\/118343"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/media\/51643"}],"wp:attachment":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/media?parent=50849"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/categories?post=50849"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/tags?post=50849"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}