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From: Philbert Chen MD
Date: 19 Oct 2004
Time: 11:24:31 -0700
Remote Name: 63.184.177.245
MRO question: Federal (DOT) drug testing protocol. Urine drug screen comes back positive. MRO determines test is positive without further testing or quantitative levels. Employee is then referred by employer to an EAP program. The SAP calls the MRO and asks for quantitative levels. If no quantitative levels have been obtained as part of the confirmation process, is the MRO obligated to order quantitative levels? In your book, The Medical Review Officers Manual, page 96, it states "DOT has advised MROs that the donor and the SAP each have the right to know the quantitative drug concentration in the specimen. If the donor or SAP asks for the concentration, the MRO should obtain and provide that value." You also write on page 185, "The SAP can ask for and recieve more specific information- for example, drug/metabolite concentrations, and the MRO's interview notes- about individual results as needed. The DOT rule, however, prohibits the SAP from receiving the drug concentration on every positive test on a routine basis. This prohibition is intended to discourage SAPs from basing their assistance recommendations on concentration values."
Since urine concentration values can be affected by many things, and are not reflective of blood levels, is there any real value to obtaining the levels for the SAPs? What is to prevent an overly zealous SAP from asking for quantitative levels all the time on every test -- seemingly on an "individual basis" but actually routine. Some SAPs seem to want the levels all the time, and others never ask. The SAPs who ask for it often do not seem to have a good reason for asking. Their rationale is that the levels help them determine "amount of usage".
Would it be better to separate the DOT "testing" process from the SAP "evaluation" process and have the SAP order levels on followup tests? The purpose of the initial testing process is to determine whether a drug is present at or above the cut off value. It is not to determine the "level of use". If quantitative levels were ordered by the MRO in some way to determine the final result, I think it would be reasonable to give the information (as it has already been obtained, and is of record). But if quantitative levels were not asked for by the MRO, then having the SAP ask the MRO to go back and get the levels seems to contradict the "purpose" of the testing. Your thoughts?
Respectfully,
Philbert Chen MD MRO
217-443-5611 office
rx7pc@earthlink.net