A Medical Review Officer (MRO) is a licensed physician responsible for receiving and interpreting laboratory results from an employer’s workplace drug testing program. The MRO acts as an impartial gatekeeper, ensuring the integrity of the testing process and protecting the medical confidentiality of the tested individual. The MRO’s role is to scientifically and medically review any non-negative drug screen to determine if a legitimate medical explanation exists for the result before it is reported to the employer. This prevents an individual from being unfairly penalized due to a legally prescribed medication or a confirmed procedural error.
Defining the Medical Review Officer
To serve as a Medical Review Officer, an individual must be a licensed Doctor of Medicine (MD) or Doctor of Osteopathy (DO). This medical background ensures they possess the necessary clinical knowledge regarding pharmacology, toxicology, and controlled substance abuse disorders to accurately evaluate drug test results. This expertise allows the MRO to understand how medications and medical conditions affect a laboratory report, moving beyond a simple pass/fail interpretation.
Beyond a medical license, MROs must complete specialized training and pass an examination to receive certification from a nationally recognized board, such as the Medical Review Officer Certification Council (MROCC) or the American Association of Medical Review Officers (AAMRO). This qualification must be renewed, requiring updated training to stay current with evolving drug testing methodologies and regulatory changes. For MROs reviewing tests for employees in safety-sensitive positions, such as those governed by the Department of Transportation (DOT), strict adherence to federal regulations outlined in 49 Code of Federal Regulations (CFR) Part 40 is mandatory.
The MRO functions as an independent intermediary between the testing laboratory and the employer. Although the employer typically contracts the MRO’s services, the physician’s primary duty is to the accuracy of the test result and the medical privacy of the donor, not the company. This independence is fundamental to upholding the fairness and legal defensibility of the workplace drug testing program.
The Core Function: Result Verification
The MRO’s detailed work begins when the laboratory reports a confirmed non-negative result (positive, adulterated, or substituted). Before reporting this finding to the employer, the MRO must initiate a confidential interview with the tested individual (the donor). This contact is typically attempted at least three times within 24 hours to ensure the donor has a chance to participate in the verification process.
The objective of this interview is to determine if a Legitimate Medical Explanation (LME) exists for the substance found in the specimen. The MRO asks the donor about any prescriptions, over-the-counter medications, or medical procedures that might account for the laboratory result. The burden of proof rests with the donor to provide documentation, such as a valid prescription or medical record.
If the donor claims a valid prescription, the MRO verifies the information, often contacting the prescribing physician or the pharmacy. The MRO must confirm that the prescription is current, the dosage is medically appropriate, and that the drug levels reported by the laboratory are consistent with the documented therapeutic use. If the MRO confirms the LME, the result is reclassified, and the MRO reports a verified negative result to the employer.
MRO Determinations and Outcomes
After completing the verification process, the MRO issues a final determination to the employer’s Designated Employer Representative (DER). This final result is one of four primary classifications: Verified Negative, Verified Positive, Refusal to Test, or Canceled Test.
A Verified Negative result is reported when the laboratory’s initial screen was negative, or when the MRO confirmed a legitimate medical explanation for a non-negative result. If no LME is found for the confirmed presence of an illicit substance, the MRO reports the result as a Verified Positive. The MRO only informs the employer of the final determination, never disclosing the specific medical information or prescription details reviewed during the verification process.
A Refusal to Test determination is made if the donor fails to cooperate with the testing process, such as failing to contact the MRO or if the specimen is adulterated or substituted without an LME. This classification carries the same consequences for the donor as a Verified Positive result. A Canceled Test occurs if the MRO identifies a fatal flaw in the collection or laboratory procedure, or if an invalid result cannot be resolved, rendering the entire test null and void.