MRO Contract Closeout Procedures 2 — Questions and Answers
Question 1: When an employer terminates a contract with an MRO, how long must the MRO retain drug testing records before transferring or destroying them?
- 1 year
- 2 years
- 5 years (Correct answer)
- 10 years
Correct answer: 5 years
DOT regulations require MROs to retain drug testing records for a minimum of 5 years for verified positive, adulterated, substituted, and invalid results.
Question 2: During contract closeout, what must happen to specimens collected but not yet tested at the laboratory?
- They must be destroyed immediately
- Testing must be completed before closeout finalizes (Correct answer)
- They are returned to the donor
- They are transferred to the new laboratory without testing
Correct answer: Testing must be completed before closeout finalizes
All collected specimens must be fully tested and results reported before the laboratory contract can be officially closed out.
Question 3: Which document must an outgoing MRO provide to the incoming MRO during a program transition?
- Only positive test results from the past 30 days
- A complete log of all donor test results with verification status (Correct answer)
- Anonymous aggregate data only
- Only cancelled test records
Correct answer: A complete log of all donor test results with verification status
The incoming MRO needs a complete record of all donor results including verification status to ensure continuity and avoid duplicate testing gaps.
Question 4: A company switches MROs mid-year. Who is responsible for submitting the annual MIS report covering the full calendar year?
- The outgoing MRO for their period, the incoming MRO for theirs
- The incoming MRO compiles data from both periods (Correct answer)
- The employer submits directly to DOT
- No MIS report is required in a transition year
Correct answer: The incoming MRO compiles data from both periods
The incoming MRO is typically responsible for compiling and submitting the full-year MIS report using records transferred from the outgoing MRO.
Question 5: When a DOT-regulated employer closes its drug testing program contract, which agency must be notified if the employer is subject to FMCSA regulations?
- DEA
- SAMHSA
- FMCSA
- No notification is required (Correct answer)
Correct answer: No notification is required
DOT regulations do not require employers to notify the FMCSA when terminating a drug testing service contract, though internal recordkeeping obligations remain.
Question 6: During closeout, a split specimen previously requested by a donor is still pending at the secondary laboratory. What is the correct action?
- Cancel the split test and issue a final negative
- Allow the split test to complete before finalizing closeout (Correct answer)
- Defer to the original MRO result and close the contract
- Notify the donor that the split result is forfeited
Correct answer: Allow the split test to complete before finalizing closeout
A donor's right to split specimen testing cannot be revoked by contract closeout; the test must be completed and the MRO must issue a final verified result.
Question 7: What is the primary purpose of a final billing reconciliation during MRO contract closeout?
- To renegotiate service rates retroactively
- To ensure all invoiced tests match CCF records and no charges are outstanding (Correct answer)
- To determine if the employer owes DOT fees
- To calculate penalties for non-compliant tests
Correct answer: To ensure all invoiced tests match CCF records and no charges are outstanding
Final billing reconciliation ensures every billed test is supported by a corresponding CCF record and that all financial obligations between the employer and MRO are settled.
When an employer terminates a contract with an MRO, how long must the MRO retain drug testing records before transferring or destroying them?