Hello, everyone, and welcome to our MRO monthly discussion. I see that everybody is hopping online now, so we will give it another minute or so before we get started. And if you have a question, feel free to either raise your hand and we can take you off mute or you can submit it via the chat box. So we have not received any incoming questions thus far, but I'm going to turn it over to our faculties, Dr. Martin, Dr. Smith, and Christine, Chris Pazak, right, correct? I apologize. Are you a doctor? No. No. Okay. Okay. I just wanted to make sure that's correct. So I'll go ahead and turn it over to you. And if I get anything, I'll go ahead and facilitate those. So welcome, everybody. Thanks for chiming in here on a mid-March evening. Hopefully everybody's weather is as nice as mine, unusual for Sioux City, Iowa. We got 70 degrees today, sunny. I had to switch my computer around so I wouldn't get the glare from the window. That's partially due to the nice weather, partially due to daylight savings time, which I think is okay. I'm not sure. We talk back and forth on that all the time about whether we should keep that or not. Better be careful. My agricultural-based friends would probably not like me saying that. But anyway, in the world of MRO work, I'll yield to my colleague, Dr. Smith, but I'm not sure there's been a lot of change, to be honest with you. There's been a lot of talk of change, but not a lot of change. So we're on a holding pattern with regards to oral fluid, and there's lots of reasons behind that. We're on a holding pattern with the opioid changes that HHS adopted, but it seems like DOT is probably not going to adopt any time soon. We don't really know. And then, of course, in the non-regulatory world with the individual states, we still are learning with the states on the marijuana changes, and of course, trying to keep up with all that stuff sometimes can get a little daunting, tracking particularly the states on the West Coast, California and Washington in particular, that have adopted these rules that if you're going to test somebody for THC, you only can do it with a psychoactive substance, not any derivatives of said substance, which presented a little bit of a challenge for some people. So anyway, I'll turn it over to you, Donna, if you have any additional things to say about that, or any new things to say. Sure. Well, probably the thing that the most buzz that I have seen that ultimately may be of interest to medical review officers is that it does appear that there is going to be an accelerated attention to the issue of rescheduling marijuana or rescheduling cannabis from its current status as a Schedule I drug to a Schedule III drug. And I am very sorry, Dr. Martin, but I do know that two days ago, there was a 272-page report that was released from HHS to DEA, and I have not read it. I instead read a great novel about baseball. So I think you chose wisely. Yeah. So I'm very derelict. But at any rate, so that, obviously, that may have a big impact. Right now, it looks like what is being proposed, and the three prongs part that I did read in terms of a summary of the document is that there is enough research that shows that marijuana does not fully meet the criteria of being a Schedule I drug in terms of its addictive potential, in terms of its impact, impairment, and toxicity, et cetera. Number two, which I was somewhat surprised at, I haven't, I guess I have not read the entire report, but the conclusion was that there is ample science, use that in quotes and end quotes to support that marijuana does have bona fide medicinal or medical uses. It mentioned particularly in the treatment of anorexia, in the treatment of seizure disorders, and interestingly enough, as an analgesic or pain medication. And then, of course, the third prong, if you will, of this report apparently is saying that they do believe that either the FDA is going to have, if we reschedule it to a Schedule III, then there will have to be, quote, clinical trials. And I have no idea, Dr. Martin, how on earth we would do that. It's different than anything else we've ever done in terms of clinical trials with regard to the efficacy, the side effects, all the stuff that's involved in clinical trials for the approval of, quote, medications. So do I think that will happen before I retire? I don't think so, but you know, I have no idea. So that's on the horizon. Dr. Martin did mention that it is important if you are doing medical review officer work in the states of Washington and California for non-federal testing. In Washington in particular, the statute applies to pre-employment testing only. And so you cannot use a urine specimen, if you will, for pre-employment drug testing in the state of Washington. It has to be either oral fluid. You can't use hair testing because unbeknownst to a lot of people, hair testing also does identify and detect the non-psychoactive metabolite THCA. The thing to know, though, about Washington, and again, it puts a lot on the MRO, and it's really not the MRO's duty or responsibility, but many of your employers that you're working with will expect you to know this, is that Washington does have a fistful of exceptions. So people that are applying for jobs as firefighters, as police officers, as a whole host of other things are exempt from this, and you can continue to do pre-employment testing for any form of cannabis or metabolites. California does not just apply to pre-employment testing. It applies for all of the testing in California. It has virtually no carve-outs. So that's kind of interesting. And what that essentially means is that if you have non-federally mandated employees, employers who are doing drug testing in the state of California, they either have to remove marijuana from their urine drug panel and continue to test, or they could go to, again, an oral fluid panel that does include cannabis marijuana in terms of THC. So that's kind of a summary of that. Do I think that there are going to be more states that are going to adopt this language relative to the psychoactive versus the non-psychoactive? And I think that that's a good possibility. Tangential to that is the issue. And again, looking at what is being published in some of the journals, some of the reports out of the National Highway Traffic Safety Administration and other safety organizations, there's a tremendous debate now about impairment and per se levels of THC, the psychoactive component. There are, I think, seven states, I could be off one on that, that do have per se driving under the influence or driving while impaired standards for THC and blood. Now, that's as far as I can go with a general statement, because in one state, it is one nanogram per deciliter of blood that is the per se level for driving under the influence or driving while impaired. In another state, it is 10 nanograms. So it's 10 times, if you will, that they have established. And it's looking like in terms of a lot of the roadside stuff that is being done, etc., that we are way, way, way far away from being able to establish a per se level for driving under the influence or driving while intoxicated based on a THC level in blood. And people are kind of up in arms about that. And again, I'm old enough to remember, it took us 40 years to establish the per se level for alcohol. That didn't happen overnight. And I think that the journey to do that with THC is absolutely far more complex than with alcohol, because it is a lipid soluble drug, because there appears to be a lot of difference relative to naive users versus regular users. The whole issue with even with regard to the route of administration in terms of oral ingestion versus smoked and all of that. So where is that going to end up? I don't know. One thing that if people ask you, is there any test I can do that establishes impairment from the use of marijuana or cannabis products? And you can there give a resounding no. You want to add anything to that, Dr. Martin? No, I think you summarized it pretty well. I think the early call, I'll be careful about how I use my words here, but the folks that were advocates of driving under the influence or driving under impaired laws with THC, I think we're quick to try to adopt the five nanogram per milliliter level that's in Europe, which is sort of been the default standard. Again, no science behind that, really. And that was sort of kind of like the shrug your shoulders. OK, let's everybody agree to accept this sort of thing. And I think some very learned people asked some very good questions about, well, does that really make sense? And then the debate rolled into, how come we can't get better tests that tell us better information? Well, it's because the nature of the drug, for crying out loud. It's not that, you know, that it isn't one for trying. I mean, people have been trying to figure this out for a long time, but it just is the nature of the beast, so to speak. So, so here we are with the great societal debate, right, as to where are we going to go with this? And, gosh, I don't want this to turn into a discussion about, you know, what people think is right from a societal standpoint, because there's all kinds of things that sort of throw themselves into that deal. But anyway, hey, we've got some questions in the chat. Wow, what a deal. OK, so let's go there. OK, there's a long one. I'm going to have to read this. Occupational medicine physician and MRO, and congratulations, so am I. My hospital system I work for is doing a cross-training campaign in our occupational health department. One of the leaders, but not my supervisor, approached me and asked for backup purposes to get training to do urine collection and breath alcohol. Isn't it a conflict of interest for an MRO to review a drug test he collected? Also, the chain of custody will have my name and signature twice a urine collector and an MRO. Well, the answer is it's not a conflict of interest. Dare I say when I was with a previous employer in the UnityPoint system in Sioux City, Iowa, I was the only Y chromosome individual in a building that consisted of 15 people. And so guess who gets asked to come do the direct observation for males? Me. Raise my hand. I'm the only one in the building. So, yeah, I mean, there are certainly situations where I, as the MRO, or also the collector, the observer, and there's nothing wrong with that as long as you, of course, know what you're doing and documenting and go through the appropriate, right, collector training, right, important stuff, and make sure that you, you know, are following all the rules in that regard. Donna, any comments? No, the only thing, and this goes way back to when we wrote the first versions of 49 CFR Part 40, the procedures for drug testing, urine drug testing at the time. And the only provision we made for a conflict of interest is that we did not allow medical review officers to review laboratory test results from a laboratory that they were employed by, that they had a financial or other interest in. And again, I think that whether it makes any sense or not, the reason for that distinction in relationship to, well, then why wouldn't you prohibit a collector, is because there's something in between, okay, the collector and the medical review officer, i.e. the laboratory. So that's really, that was addressed in the, I mean, we thought about that in the very beginning, Dr. Martin. Yeah, yeah, for sure. You bet. So thanks for that question. Another question is, someone's taking the test this weekend. Congratulations. Assume all the information in the digital syllabus is up to date for testing. I think the answer to that is yes. And this, without getting too far into the weeds, and I'll ask Krista to weigh in on this because she can verify if what I'm saying is correct, you have to understand that there is some lag time between when something changes in the rules and regulations to when it actually is going to be incorporated within a certification test. And there's a lot of different reasons for that, most of which are in the realm of the psychometric discipline where, you know, there's a process that's involved, right? As far as how to write a good test question and making it so it's not biased, beta testing the thing and graph scoring the thing. If you don't know what that is, don't worry about it. But making sure that, you know, the thing is valid as far as a question is concerned. That is more of a complex process than what a lot of people give it credit for. So the current version of the certification test does reflect what is in the digital syllabus, and I don't think I'm misspeaking about that. Am I, Chris? No, you are not. You're absolutely correct. Both have been updated with the regulation changes, and it does take, it can take up to a full year before new material is put into the exam. You know, the first thing we have to do is get any old material out of the exam so that we don't have any questions that people don't know how to answer. And so that process was done fairly quickly, and then you move into the let's get some new questions on the new information. You've got to get the committee together. So it is a very long process, and I think even more so with this one, with oral testing not really happening, we're not in a rush to inundate the exam with a bunch of oral fluids questions that people aren't going to be using and are most likely going to have to relearn when they're finding laboratories that are doing this. Yeah, I think that's a very good point, Chris. I know I've talked to a lot of MROs that worry about that. They think, oh my gosh, you know, this whole oral fluid thing is a new thing. And there's some, I think, misperception that maybe there's, it may be a waiting in the exam that because it's newer, let's put it that way, that there's going to be this plethora of focus of questions on that, and that is not the case. So just to kind of calm anybody's fears about that. It's not the case with any particular topic. We only have 100 to 110 questions to test you on an entire broad field. So we can only ask so many questions on oral fluid versus the different urine testing. So it isn't going to be a ton of questions on oral fluid on the exam, even once it happens. Yes, very good. Okay, here's another question. If the creatinine is between 2 and 5, do you ignore ranges of specific gravity listed below in summary and order a retest under direct observation? This relates to question 66, tab 10.39, slide 77, where creatinine is 2.5, but specific gravity, not less than 1.0010. Oh heavens, I'd have to get to the slide here. Taking two. Yeah, basically the thing, and it's always difficult to remember all of these, the less than, equal to, greater than, equal to, et cetera, with these creatinine levels and the specific gravity levels. But two to five is a unique category, if you will, under the DOT rule. And so when you get a laboratory report that has creatinine between two and five, it's not less than two, it is not greater than, or five or greater, that is going to automatically require a recollection under direct observation. You don't have to look at anything else with regard to that. Does that answer the question, Dr. Martin, or no? I think so. I think that gets at it. I was just looking on this slide. I think maybe this is one of those slides that might kind of give people a false sense of what the information is on the slide. I'm not 100% sure on that, but what you have stated is correct. And I think that is by far the easiest way to remember it, right? If it's between two and five, that's what you do. I should have a copy of the syllabus here, but I know that there is in one of the tabs that we actually, Dr. Peterson and I and Dr. Pete put together a chart. I don't know where that is, though. I don't have it in front of me. That's what I'm scurrying, trying to find. Okay. All right. But that's a really good thing to look at in terms of as you study for the exam. And there's no easy way to do it other than memorize it. And even if you forget it next week after you take the exam, you can always look it up. Exactly. Exactly. Good point. Okay. Very good. Good. All right. I don't know, Vicki, maybe we could get that individual's contact information, and once we find out where it is, give him the reference for that chart. I think that's an excellent idea. I will send an email to him directly following this, and I will copy you both on that with the stated question. Okay. Very good. All right. Let's see here. What else do we have? One thing I'll point out while Dr. Martin is looking is we are going to have a new issue of the newsletter come out soon, and we have a summary article from Dr. Smith about the marijuana testing in California and Washington that will be included. So, it's free. It's open to all. I'll put the link to the newsletter in the chat. But it is a nice summary, and it will be a good reference for you. Very good. Somebody just said, hi. Well, hi back, Gail. Thanks. We have such friendly attendees. It's nice. One other thing just to mention. I don't know whether anybody's asked about it, but it was about a month and a half ago now that the Department of Health and Human Services has proposed that fentanyl testing be added to federally mandated testing, which would be the Nuclear Regulatory Commission testing, Department of Transportation testing, and testing that is done under the HHS mandatory guidelines, which governs testing for federal employees who are in what are called testing-designated positions. They're basically security and safety-sensitive positions. But at any rate, that has been proposed. At the last couple of meetings of the Drug Testing Advisory Board, which functions to advise the Department of Health and Human Services on not only the adoption of the panel and changes to the drug testing panels, but the cutoff levels and everything relative to those scientific and technical, if you will, aspects, have had some lively discussions about whether or not the testing, not only in terms of the cutoff levels, but whether it should be testing both for parent fentanyl and for nor-fentanyl, and if so, what are the limitations of being able to identify and substantiate both the parent drug and the nor-fentanyl metabolite. This is harder than it was before, because now HHS, even though we don't have it out there, whenever they are changing anything to the panel, for example, for urine drug testing, they are going to make a parallel change for oral fluid testing. So that makes it a tougher topic, because are there reagents available to test for nor-fentanyl on an oral fluid specimen, and if so, what are the sensitivity levels and what are the, you know, what can be done to make that, again, applicable for both oral fluid testing and urine testing. So I am afraid that we may be facing what we faced years ago when we were adding ecstasy, MDMA, to the panel. It was during the height of the, quote, ecstasy rave, you know, kind of epidemic, or at least the higher incidence, and it took us seven years to get MDMA added to the federal drug testing panel. By that time, the raves were not a rave anymore. They were not as much of a deal. They had gone on to many other different drugs, and who knows, the whole issue with fentanyl has also been a real problem, because fentanyl, there are probably 26 different types of fentanyls that are illicitly produced with just one change in ion or one change in a group, and so carfentanil is the whatever, and so that has also made it difficult. I think they will persevere. I don't think they cannot do it, but that may be at least a year before we see that finally added to the panel. Right. Good points. Okay, let's go to some of the other questions now. I've had some more appear in the chat. What happens if a positive DOT result does not get uploaded to the clearinghouse within two days? Well, Dr. Teiss, they come to Sioux Falls, and they, you know, take your license away, and no, I'm just kidding. Well, what happens? Well, it doesn't happen. I'm not sure there's any police action right now, Donna, is there? I mean, it just, you know, you raise your right hand, and you say we're going to try to follow the rules, and if, you know, you kind of slip up, then you try to get it in there as soon as you can. You know, I can tell you that if you were ever subject to an audit, and a medical review officer, or a medical review officer company, in terms of DOT audits, is generally, that will be done either by the Office of Drug and Alcohol Policy and Compliance, and, and, or, like, if you are the medical review officer, let's say, for using this as an example, J.B. Hunt Trucking, okay, and J.B. Hunt Trucking is undergoing an audit by the Federal Motor Carrier Safety Administration branch. When they audit that company, and as they look at the positive tests, and they will cross-check that for when they were reported to the clearinghouse, and if you, as the medical review officer, are reporting those only on the first of the month, you know, X number of days beforehand, the action by FMCSA would, interestingly enough, be taken against J.B. Hunt, okay. They would have a finding that says that their service agent is not complying with Part 382, Subpart H, or whatever that is, the clearinghouse requirement. And then, you know, and they may be fined for that, like they would for other areas of non-compliance, and J.B. Hunt is likely to, if they get a $10,000 fine because Donna Smith and Dr. Soles, as their MRO from Workforce QA, has been doing this and not complying, of course, guess who they would come to to pay that fine. It would be us as the MRO. But that's really the only way that that is going to be. You should all, even if you've missed the two days, or you've missed the three days, you should go ahead and report it as soon as you find it. And you do not have to, you do not have to submit anything to the clearinghouse in terms of saying, oh my, oh my, I'm late, I'm late, please accept my apologies. Nope, you just enter it into the clearinghouse. Okay, Dr. Schwartz has asked this question, and I think this has come up before I know the slide that he's talking about, and this has to do with regards to MROs and what they do with flaws, correctable flaws, and uncorrectable flaws. And I know on this particular side, you know, the flaws, you know, that are fatal, right, we know what those are. And what we're talking about here are the ones that are correctable, right. So there's a whole list of things on this slide that talk about those things that if they're not corrected, the MRO has to cancel the test. But there is one part of this slide that he's referring to, and it's in the scenario where the specimen temperature box is not checked, and there's no remark, okay. So it's kind of what I call a double-edged sword. There's a request for you to try to obtain a statement of correction on that, but that is not one of those scenarios where you cancel it if you don't get that corrected statement. And that is the singular thing that's on that slide that I think maybe trips some people up, and Dr. Schwartz, I take your points here purposely. I think one of the maybe edits of subsequent slides might be to separate those out on different slides so that it's clear to people that we're talking about different scenarios there. So thank you for bringing that to our attention. Okay. Oh, Dr. Jackson, I think answered his own question. Records, right, okay. Drug test results and the rest of the patient medical chart, yes. Please keep those things separated. I went round and round and round with some hospital people about this at one point in my career, and finally they got it, but only after I had to sit there and explain it to them like 14 different times. But there's, I mean, there's tons of reasons to do this, not for which is, you know, just confidentiality issues, but, you know, what if you had a patient record or a hospital record that other providers can access? And by other providers, in our electronic medical world that we live in nowadays, it's not just physicians, but it's nurses and physical therapists and, you know, it seems like everybody under the sun has access to these types of things. Well, you know, the job here is to try to maintain confidentiality as best as we possibly can with these things. And certainly keeping those things separated from a normal patient chart goes a long way to try to help with that. So definitely. Dr. Smith, you might know the answer to this. Does anyone know of a laboratory that tests for anabolic androgenic steroids? This is, this is a thing obviously in the sports world, right? But also I know oftentimes is something that is part of a post-job offer or pre-employment tests for certain occupations, police officers, firefighters, and so forth. Yes. Yes. Many of the SAMHSA certified drug testing laboratories do test for anabolic steroids. Quest Diagnostics, one of their laboratories does. CRL, which is a clinical reference laboratory, does. LabCorp has one facility, one laboratory that does do an anabolic steroid panel. Let's see. Probably the laboratory that I know that has the broadest, you know, anabolic steroid and precursors and whatever panel is a laboratory called NMS. What does that stand for? I can't even remember now. It's in Pennsylvania. It's a reference laboratory. Anyway, they, they do have a much broader panel, but let me tell you that that panel can cost over three or $400 per test. So I think you are better off depending on the circumstance that you are better off to contact Quest Diagnostic on their workplace side and look at what anabolic steroid panels they have available. Generally, there are somewhere between seven and 10 of the major anabolic compounds. Very good. Thank you. Gil has made a comment that he's a family medicine physician working in occupational medicine and was asked to get certified as an MRO. Welcome, Gil. This was me back in 1994. So gosh, 30 years of, you know, change from being trained in family medicine to a 30-year career in occupational medicine. So welcome. It's been a pleasant ride. I hope you enjoyed it as much as I have. Rachel has got another question. Okay. In regards to my question above on reporting positives of the clearinghouse, if there was an audit with a fine passed on to the clients in regards to a 382 Part 40 violation, how far does FMCSA go back to review records and can they impart fines? So if it occurred in 2023, reported in 2024, how long should I worry about? And she is quick to put the disclaimer in there, I was not the MRO at the time. Oh, goodness. Donna, practically, how do people deal with this sort of thing? You are responsible for keeping any non-negative result record, your MRO interview, your determination, etc., where you have verified it as positive, as adulterated, etc., right, for five years. Any drug test result that you have canceled, all right, for fatal flaw, uncorrected flaw, whatever it may be, you are responsible for keeping that record and having it available to an auditor upon request for two years. Results that you have signed off on or your staff has signed off on and have been, now I'm talking only about DOT results, anyway, that are negative, you only are, the auditor will only be able to look at those from an MRO perspective for one year. Now, when the employer, likewise, has the same requirement, so in terms of the record retention, so again, let's use the example J.B. Hunt is being audited, right, generally speaking, under FMCSA, the auditor is going to tell J.B. Hunt, we are going to look at all of your drug testing records for the past two years. That's what they generally do. It's just, it's not feasible to go further back than that in terms of when they're doing an on-site audit, etc., so it's usually two years. They will tell the company that when they schedule the audit. These are the records you have to have from January 1st, 19, excuse me, 2022 to, you know, the current date. So, again, if they are looking at a result, a result, a positive result, that you are not the current, that you are not the MRO for, J.B. Hunt, though, will have to have that result from that previous MRO, and then the auditor, if there's a question relative to that, then J.B. Hunt would, or excuse me, the auditor, the FMCSA auditor, would contact the previous MRO for further clarification. Very good. So, 5, 2, and 1 is what you need to remember. All right, anything else good questions this evening folks All right, I see nothing in the chat Okay, so any any? Final words Donna. Well, what's there one question that maybe we should punt to Chris about how should I study? Oh, yeah Chris You're right. I think I might have breezed through that one by mistake. So Chris is going to tell you how to get ahold of the Templates and all that kind of good stuff So there is a spot on our website If you go to the website and go to exam registration, there's a exam preparation section It's definitely worth looking at that. The blueprint is there. It will tell you what topics are covered It'll give you the percentages that are covered in the exam That you know regulations is 50% of the exam So I can't emphasize enough how important the regulations are. I think anyone that's ever taken it will tell you that Keep in mind. It's an open book exam and you don't have a lot of time to look things up So be prepared before you start put together your little cheat sheet put all your confirmation levels So you're not looking up those things as you're going through have all your reference material materials Easily available so that you're not trying to find the link to go to the regulations website You know the other thing I would tell you the regulations there is a spot where you can download a PDF of the regulations I recommend you do that it's a lot easier to search on a PDF than it is to try and go through that website as you're going and and a Lot of what you're going to look up is going to be there because on top of the regulations That's also going to cover all the questions on collections So I'd take a look at the blueprints I would put together your little you know cheat sheet and I would definitely have the regulations open ready to go ready to search before you start the exam as well as any other materials your Syllabus, you know the course information you want to keep all of that easily available Yeah Very good. Very good. One last question appeared and that's how to approach immunoassay interference. I'm assuming this means a Laboratory report that says that the test could not be completed because of immunoassay interference Call the laboratory you call the certifying scientist and you have a conversation with them about You know, what do they think is going on? You know a lot of times they can be very helpful With regards to the details about is there an interfering substance that might be in the urine? Is it characteristic of something that they typically see with this sort of thing, you know? They can be very very helpful with respect to that before you have to Then have that MRO interview and have that unusual conversation. I always sell today with the donor About you know, well, we got this result back and it seems to be some interfering thing. Is there medication that you're taking something else going on and of course, you know, we're roundabout getting at the Concept of adulteration right about people that are trying to do things and sometimes that's the case Sometimes there's legitimate reasons for this so have that conversation with the certifying scientists. They can be very very helpful in that respect Yeah, I think I can't emphasize enough what dr Martin is saying in terms of talking with the certifying scientists or the lab director or whatever because they They're doing thousands of these specimens a day And so, you know you or I and an MRO practice may see, you know Immunoassay interference once out out of you know Once every other month or something like that but they're seeing these on runs every day and They do they are able to say and one of the things that in talking with the dr Kunz's and the dr. Samples and the dr Costantino's etc over the past couple of years is that the proliferation of dietary supplements? Okay has really been kind of a culprit if you will and some of the immunoassay Interference issues and at least they can give you an idea This is what we've seen, you know on a person's on these kind of this group of Supplements, etc and I know that we would like to perhaps Kind of bend the pendulum this way that if there's an interfering agent It means the person has tried to adulterate or cheat I don't think that that's I don't think that's where the starting point should be. I really don't I think now again You ultimately probably are going to Declare it as a cancelled test because it's going to be impossible Even talking with a good certifying scientist to say well Can you run a test and tell me was it supplement Excel supreme or wasn't it? You can't do that, right and so ultimately you're probably going to end up canceling the test and having a Recollection and that collection will be under direct observation. Why because again, you're at least then eliminating the possibility hopefully of being able to you know to At the time of collection being able to manipulate the test But you know assay interference should not be in this day and age equated immediately with an attempt to adulterate a Specimen and we just couldn't catch it Yeah, there's there's a lot of helpful information that I've gained over the years from those discussions with certified scientists about About trends that they see right? So, you know if there's some Dietary supplement some vitamin some new thing It seems to be like, you know, the flavor of the day. It seems very popular Yeah, you know, there's a bunch of them You're right all the sudden, you know that they see with that type of interference pattern and then you know Then that side kind of slowly goes away and then you know, maybe a year later Then there's another one that pops up. That's kind of a fattish type of thing. So It does happen for sure Okay, I See no other things in the chat any hurting words Donna I don't have any anybody have anything that they want to ask verbally Well, I'm still trying to figure out Which NFC central team has got which others player today? This is this has become I don't know we get Vikings now that are bears and Packers that are now Vikings and I can't keep track of all this and it's just driving me absolutely bananas But I'll figure it all out. Hopefully by the fall. Yeah Dr. Jackson the five to One that I mentioned that was my little whatever for how the length of time that you as a medical review officer Need to keep your records for DOT or federal drug tests. So for any one that is a positive and adulterated you need to keep the Everything that you've got your interview notes your final determination your copy of the CCF to for five years For any tests that you end up cancelling you need to keep that documentation For two years, even if it was a fatal flaw if it was a Uncorrected flaw if it was an invalid if whatever it may have been You need to keep that record for two Anything that is reported out by you as a negative Even if it's been signed by your staff member because you don't have to sign negative results under the DOT rule Then that's a one-year record retention requirement. So that's the five two and one Oh one thing I should mention. Dr. Martin People were asking me last just last week. We had a new medical review officer. Come on staff at at workforce QA and said I don't have to sign this the CCF to anymore. Do I because now we have electronic signatures. Guess what? No, we do not The Department of Transportation still has not approved electronic signatures for the Department of Transportation by medical review officers for again for the negative And the cancelled test that has to be a pen and ink even if the CCF itself was a An electronic or an ECCF in which a copy then of copy two Is is is obtained by you you have to print that copy that image pen and ink sign it And then scan it and that remains your your quote your electronic record But it does have to have a pen and ink signature. No, my assistants just love that But you know, it's it's life right, you know, we don't get rules sometimes that we don't like but we have to follow them All right, good stuff, uh anything, uh, Chris or Nikki No Nope just as a reminder to our attendees if you do think of any other additional questions You can email education info at acom.org And i'm happy to get you connected with our faculty And just thank you all for joining and thank you to our faculty for your time this evening And we are not going to meet in april. Is that correct? No, we will we are going to meet in april, but we're not going to meet in may because it's the week of aohc Okay. All right. Perfect. Thank you Goodbye, everybody. Have a good evening

MRO monthly discussion

immunoassay interference

drug testing results

certifying scientists

record retention

positive results

adulterated results

pen-and-ink signatures