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3) Review of the laboratory result by a Medical Review Officer (MRO)
The MRO is a licensed physician who works for the drug/alcohol testing vendor. The MRO
has knowledge and clinical expertise in substance abuse disorders and must meet specific
federal requirements. The MRO is an independent impartial gatekeeper to the accuracy and
integrity of the CDL drug testing program. As a safeguard to quality and accuracy, the MRO
reviews each laboratory test result and will rule out legitimate medical explanations before
verifying any non-negative laboratory result. After receiving the laboratory report, the MRO
will:
Review the paperwork for accuracy.
If the laboratory result was negative, report a negative result to the commonwealth.
If the laboratory result was positive, conduct an interview with you to determine if
there is a legitimate medical reason for the laboratory result:
o If there is a legitimate medical reason, for example, you were taking a
prescription medication that caused the laboratory result; the MRO will report
a negative result to the commonwealth. You must provide acceptable
medical documentation to the MRO to establish a legitimate medical reason.
o If the MRO determines that a prescription medication you are taking may
impair your ability to operate a CMV safely, you will have 5 business days to
have your physician contact the MRO to discuss your medication and
potentially alleviate the MRO’s concerns.
o If your physician does not contact the MRO, or does not alleviate the MRO’s
concerns, the MRO will report a negative with a safety concern result to
the commonwealth.
If you do not already have a current CDL Employee Prescription Medication
form (Appendix B) on file with the Office of Administration’s Bureau of
Workforce Support (OA/BWS), you will be removed from safety-sensitive
duties until you obtain a properly completed form from your medical provider
which establishes that you can operate a CMV safely while taking that
prescription medication(s), or that you are no longer taking that prescription
medication(s).
o If there is no legitimate medical reason, the MRO will report a positive result
to the commonwealth.
If the laboratory result is adulterated or substituted, conduct an interview with you
to determine if there is a legitimate medical reason for the laboratory result:
o Adulteration includes adding substances to the urine specimen.
o Substitution includes submitting a specimen that is not your urine, such as
another liquid or another individual’s urine.
o If there is a legitimate medical reason, the MRO will report a cancelled result
to the commonwealth. You must provide acceptable medical documentation to
the MRO to establish a legitimate medical reason.
o If there is no legitimate medical reason, the MRO will report a refusal to test
result to the commonwealth.
If the laboratory result is non-negative (positive, adulterated or substituted), and
you refuse to discuss the results with the MRO (including not returning phone calls to
the MRO), the MRO will report that non-negative result to the commonwealth.