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REGULATORY ISSUES AND MRO
ROLE
Approximately
50% of the exam items are within this competency area Competency Statement
The MRO must be and
remain knowledgeable about applicable rules
including federal MRO guidelines, and federal
agency regulations which impact organizations for
whom the MRO evaluates drug test results. The MRO
is often called upon to assist clients in the
implementation of legally defensible policies and
programs. Therefore, the MRO must be able to
advise organizations about both regulated and
non-regulated drug and alcohol testing
procedures. Knowledge in the area of regulatory
issues and MRO responsibilities will enable the
MRO to:
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interact effectively with other
program participants, including: employees,
employers, DERs, SAPs, TPAs, other health care
workers, laboratories and collection sites.
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advise employers in the
development and implementation of effective
workplace substance abuse prevention program
policies and procedures.
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comply with applicable laws and
federal regulations in the review,
interpretation and reporting of drug test
results, including confidentiality,
documentation, record maintenance and storage,
and release of information.
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develop a standard operating
procedure for conducting an effective MRO
interview which complies with applicable
regulations.
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recognize and address the major
legal and regulatory issues that face the MRO,
other service providers and employers in the
establishment and implementation of drug testing
programs.
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serve as an expert consultant or
witness on matters involving drug testing.
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adhere to and uphold the
professional code of ethics relating to drug
testing.
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evaluate and help manage
collector services, laboratory services, and
other services in the program to ensure
reliability, confidentiality, efficiency,
appropriateness, and promptness of these
services in response to the employer’s needs.
Topics on Examination
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MRO Role in federal testing
programs
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Federal regulations & programs
(DOT, DOT Agencies, DHHS, NRC, EEOC, etc.)
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Communication & reporting of
results to employers, employees & other
participants (DERs, SAPs, TPAs, etc.)
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Recordkeeping
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Company substance abuse
prevention policies
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Medical-Legal issues
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Confidentiality
References
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Swotinsky RB, Smith DR, The
Medical Review Officer's Manual. Beverly
Farms, MA, OEM Press, 4th ed. 2010,
pages 1-56; 131-190; 201-216; 279-288.
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Peterson KW, American College of
Occupational and Environmental Medicine, Drug
and Alcohol Testing Medical Review Officer
Course Syllabus and Resource Manual, updated
annually. Sections on regulatory issues and MRO
responsibilities.
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American Society of Addiction
Medicine, Medical Review Officer Course
Manual, updated annually. Sections on
regulatory issues and MRO responsibilities.
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U.S. DOT Office
of Drug and Alcohol Policy and Compliance,
“Procedures for Transportation Workplace Drug
Testing Programs” Title 49, Code of Federal
Regulations, Part 40. Washington, DC,
www.dot.gov/ost/dapc
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U.S. DOT Office
of Drug and Alcohol Policy and Compliance, “Q &
A’s”, Title 49, Code of Federal Regulations,
Part 40. Washington, DC,
www.dot.gov/ost/dapc
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“Mandatory
Guidelines for Federal Workplace Drug Testing
Programs”, Department of Health and Human
Services:
http://www.drugfreeworkplace.gov/Dtesting.html
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SAMHSA,
“Medical Review Officer Manual for Federal
Workplace Drug Testing Programs”:
http://www.drugfreeworkplace.gov/Dtesting.html
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MRO Code of Ethics;
Established by the Medical Review
Officer Certification Council Board of
Directors, July 15, 2003; updated 10/8/08;
http://www.mrocc.org/code.htm
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U.S.
DOT Employer Guide:
http://www.dot.gov/ost/dapc/employer.html
GENERAL SUGGESTED REFERENCES & ON LINE RESOURCES
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