By Dr. William D. Brooks, American Association of Medical Review Officers (AAMRO), Founding Member, Past V.P., Trainer, Advisory Board Member GAC & Education Committee NDASA, OStG

Today’s litigious marketplace requires all participants in a drug testing program to operate at full capacity to avoid errors. As most of you know, the Medical Review Officer (MRO) is the last line of defense, so we are the professionals in the process who are responsible for getting all errors corrected to salvage a drug screen. This is not always an easy task, and in some instances cannot be facilitated, so the screen gets canceled. This process of repair is very time-consuming for the MRO, their staff and the company we are representing.

The Collector in the process of drug screening has one of the most important roles. They must ensure the donor is who they say they are, they must minimize the risk of being cheated in the collection process and they must ensure all parts of the collection process are completed from start to finish. When a Collector can do everything as required it helps the MRO immensely.  

There are five key ways Collectors can minimize problems for the MRO:

1. The most consistent challenge the MRO faces is the clarity of the Custody and Control Form (CCF). The Donor’s and Collector’s handwriting must be clear. This is critical to the MRO staff who initially field all non-negative results and get them to the MRO. It is incumbent on the Collector to be the handwriting police and ensure all areas are legible. When I talk about the clarity of the CCF, I am not only talking about the handwriting, but the clarity of the faxed or scanned copy that gets sent to the MRO. All too often, this part of the process is overlooked for speed. If the CCF is too light or dark, it will not scan/fax well and will potentially be illegible on the MRO end. The MRO then needs to contact the Collection Facility/Collector to try and improve the quality of the paperwork. When we can’t read the CCF, it interferes with the MRO’s ability to efficiently contact the donor and ultimately the employer with a final result. It may take multiple tried to determine the correct contact information or the MRO is put in the position of having to put on their Inspector Clouseau hat to figure out who performed the collection and how to reach that person.

2. The next challenge Collectors can help with is marking the temperature, which requires an affidavit if it is omitted, once again slowing the process dramatically.

3. Collectors must check to make sure they have signed the CCF. The absence of the Collector’s signature can result in a fatal flaw and require the drug screen to be re-collected. In some instances, a second collection is not allowed and therefore the donor simply walks away and goes back to work without consequences after a presumptive positive drug screen. If a second collection is required, the drug of choice may be gone from the Donor’s system, as it could take several days to get a Donor in for another collection. We may lose our element of surprise it was a Reasonable Suspicion, Random, Return to Duty or Pre-Employment screening.

4. Adequate notes must be included on the CCF for any kind of collection irregularity.  This could be Temp out of Range with a T/O on both CCFs acknowledging a second collection and a note that the observed collection was completed with the CCF number listed. Note if bluing agent was visible in the cup, or there was evidence of a hydration log or something else that could have adulterated the specimen. These are important factors that need to be relayed to the MRO.  Remember: “If it isn’t written, it wasn’t done” and no one will have all the information they need to look for other parts and pieces of the puzzle.

5. The last major hurdle is the Donor’s information and signature.  The same holds true here, if it is not legible or omitted, we may or may not be able to retrospectively go back and get the corrected information. This could result in improper identification by the MRO, inability to contact the donor or a Fatal Flaw for a screening that may not be allowed to be re-collected.

There is nothing more upsetting to an MRO than having to cancel a positive test result because someone did their job half-way – potentially sending someone back to work who puts the safety of the workplace and the general public at risk. It is solely up to the Collector to ensure all areas of the CCF are filled out correctly, completely and legibly. Without this type of diligence, the process fails.

So, I encourage all who are Collectors to pay attention to the details and make sure that ALL areas of the process are completed to the best of your ability. Leave no drug screen to be canceled because of an error that could have easily been avoided. Speed is not always our friend.