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ARN30190-AR 600-85-001-WEB-3
600-85, KSARNG, Substance Abuse Prevention & Control, 2007 Jun 1(2)
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14. Medical review officers and review of positive urinalysis drug testing results
a. This establishes policy for physicians, toxicologists, nurse practitioners, and physician assistants assigned duties as MROs in determining if a valid medical explanation exists fora positive UA drug test result. The medical review serves as a critical safeguard in the UA program to ensure that positive drug tests resulting from legitimate medications and foods are not misinterpreted as illegal drug use.
b. This applies to all physicians, physician assistants, and nurse practitioners as MROs, as well as to civilian and military forensic toxicologists that support the Army DTP. This applies only to military forensic drug testing.


AR 600–85 • 23 July 2020 32
(1) The MEDCOM Program Manager for Forensic Toxicology will
(a) Appoint in writing a doctorate level civilian and/or military toxicologist as an MRO consultant and subject matter expert.
(b) Appoint in writing a civilian and military forensic toxicologists) assigned to MEDCOM to serve as an MRO.
(c) Perform quality assurance (QA) reviews of all results reported to the DAMIS Website.
(d) Maintain the master list of certified MROs.
(2) The MTF commander, Theater Senior Medical Officer, and MSC Commander will
(a) Appoint on orders a qualified medical clinician meeting the requirements set forth in this regulation to serve as an MRO.
(b) Ensure that a sufficient number of MROs are appointed so that reviews are completed within 15 days for AD and 90 days for reserve component of receipt of laboratory result.
(c) Ensure that the MRO completes MEDCOM sponsored training and certification described in paragraph b. (3) a) and (b, below, prior to performing any MRO review.
(3) The MRO will
(a) Complete MEDCOM sponsored training and certification prior to performing any MRO review. There are two training options, both providing full certification. MROs may complete the web based training at https://iftdtl.amedd.army.mil or by attending the training onsite at the Army Medical Department Center and School
(AMEDDC&S) held annually.
(b) Obtain and maintain MRO certification by completing training and passing the MRO examination. Certification must be renewed every 3 years. Retraining can be obtained by accessing the MRO Web training module and passing the examination.
(c) Review positive UA drug test results on Soldiers for the drugs that require an MRO review as required by DoD policy. For questions contact your local ASAP office, or the BAC manager.
(d) There is no requirement for the MRO to have a telephonic or in-person interview with the Soldier as long as the review can be resolved by reference to the Soldier’s available medical record. Soldiers will be provided the opportunity to present evidence of legitimate prescription use if the electronic or hard-copy medical records show no explanation for the positive result. If an interview does occur with the Soldier, the MRO will advise the Soldier of their rights from DA Form 3881 (Rights Warning Procedure/Waiver Certificate.
(e) Findings will be updated in DAMIS for AD within 15 days and 90 days for Reserve Component by the MRO.
MRO will obtain access and input results into DAMIS.
c. Policies.
(1) Appointed MROs must meet the requirements set forth in this regulation.
(2) The MRO will report findings using only the standard reporting language contained in chapter 14. The Web- based MRO reporting system in DAMIS will provide documentation and archival records of each MRO review. A QA review of electronically reported MRO results will be conducted by the MEDCOM Forensic Toxicology Program Office. If an issue is discovered during the QA review of MRO results, the Program Office will return the results with additional comments, and a corrected review maybe required.
(3) In locations where access to DAMIS is not available, the MRO will maintain all documentation of completed medical reviews until it can be entered into DAMIS.
(4) MROs are directed to consider any legal prescription that explains the UA positive result fora controlled substance when evaluating authorized use
(a) A Soldier’s use of their lawfully prescribed and dispensed medication, for medical purposes, after the prescriptions expiration date, does not in itself constitute a violation of Art a, UCMJ and such use does not require an automatic illegitimate use finding under this regulation.
(b) An MRO determination of "authorized use" is an administrative action which does not preclude the MRO from communicating concern for controlled medication misuse to other providers or to commanders in accordance with Department of Defense Instruction 6490.08. MROs are also not precluded from communicating concern for harmful weight loss practices to other providers or to commanders in accordance with AR 600

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