MRO Contract Closeout Procedures 3 — Questions and Answers
Question 1: An MRO discovers an error in a result reported six months ago while preparing contract closeout records. What must the MRO do?
- Ignore it since the contract is ending
- Issue a corrected report and notify the employer before closing (Correct answer)
- Notify only the donor, not the employer
- Destroy the erroneous record and issue no correction
Correct answer: Issue a corrected report and notify the employer before closing
MROs are obligated to correct reporting errors whenever discovered, regardless of contract status, and must notify the DER of any changed result.
Question 2: Which of the following best describes the role of the Designated Employer Representative (DER) during contract closeout?
- The DER has no role; the MRO handles all closeout tasks
- The DER coordinates record transfer, verifies receipt, and ensures program continuity (Correct answer)
- The DER submits all specimens directly to the lab during transition
- The DER must retrain all safety-sensitive employees
Correct answer: The DER coordinates record transfer, verifies receipt, and ensures program continuity
The DER is the employer's point of contact responsible for ensuring records are properly transferred, all tests are accounted for, and the new service provider is operational.
Question 3: How should an MRO handle confidential medical information collected from donors when transitioning records to a new MRO?
- Email unencrypted files to expedite transfer
- Use secure encrypted transfer methods and obtain written authorization where required (Correct answer)
- Provide only aggregate summaries without identifying information
- Retain all medical information and never transfer it
Correct answer: Use secure encrypted transfer methods and obtain written authorization where required
Confidential medical information must be transferred using secure, encrypted methods to protect donor privacy consistent with HIPAA and DOT privacy requirements.
Question 4: A random testing pool is managed by a C/TPA under contract closeout. What must happen to the random testing pool before the contract ends?
- The pool is dissolved and employees are removed from all random testing
- The pool is transferred to the new C/TPA or employer with all current roster information (Correct answer)
- Each employee must be re-enrolled manually by the new administrator
- Random selections are suspended for 90 days post-closeout
Correct answer: The pool is transferred to the new C/TPA or employer with all current roster information
The random testing pool must be transferred intact to the new C/TPA or employer to ensure uninterrupted compliance with required annual random testing rates.
Question 5: Under 49 CFR Part 40, what is the MRO's obligation regarding test results for employees in a safety-sensitive role when the employer's drug testing contract is closing?
- Release all results to the public record
- Ensure the successor employer or new MRO receives all relevant verified results (Correct answer)
- Shred all records to protect donor privacy
- Notify the DOT modal agency of each individual result
Correct answer: Ensure the successor employer or new MRO receives all relevant verified results
The MRO must ensure that verified results for safety-sensitive employees are properly transferred to the new service agent or employer to maintain regulatory compliance.
Question 6: What is the correct process when a laboratory's accreditation lapses during an active MRO contract closeout period?
- All pending tests are automatically cancelled
- The employer must use a SAMHSA-certified laboratory; accreditation lapses invalidate future testing from that lab (Correct answer)
- Tests can continue for 30 days under a grace period
- The MRO can independently certify the laboratory for continued use
Correct answer: The employer must use a SAMHSA-certified laboratory; accreditation lapses invalidate future testing from that lab
DOT requires that all specimen testing occur at SAMHSA-certified laboratories; a lapse in certification means the lab cannot process federally mandated tests.
Question 7: During MRO contract closeout, what is the recommended timeframe for issuing final test results for all specimens in process?
- All results must be issued within 24 hours of contract end
- Results should be issued within the standard reporting timeframes regardless of closeout (Correct answer)
- Results can be delayed up to 60 days post-contract
- Only positive results need to be reported after contract end
Correct answer: Results should be issued within the standard reporting timeframes regardless of closeout
Standard DOT reporting timeframes apply to all in-process tests regardless of contract status; closeout does not excuse delays in result issuance.
MRO Contract Closeout Procedures 3
An MRO discovers an error in a result reported six months ago while preparing contract closeout records.
What must the MRO do?