Part 4—Tis is a review of the Medical
Officer (MRO) credentials. If your MRO is local, the inspector may elect to go to the office to interview him or her. If they aren’t local, they will the MRO will be contacted by phone. Inform your MRO of an inspection in advance, so that he or she will be available. Keep a file of your MRO’s training records, 5 percent review, and related documents with your files for review. If you have a Tird Party Administrator (TPA), provide copies of their certifications, such as an MRO assistant certification. You should also maintain collector certificates for anyone doing Department of Transportation (DOT) collections. Sometimes, inspectors will ask to see certificates, while other times they may ask how you know they are certified collectors. Te correct response is, “I keep their collection certificates on file.” Part 5—Tis is a Substance Abuse Professional (SAP) Review Guide.
It’s important to make sure your SAP fully understands the regulations and documentation, such as correct leter head, initial evaluation, treatment program, return-to-duty, follow-up recommendations, and testing schedule. Te SAP guidelines can be found in the federal regulations. Te inspectors will go through each of these files very thoroughly. Now you are ready for the inspection of
records. You will receive a list of records and documents necessary for inspection with your certified leter. I suggest you organize your documents in the order listed in your leter. You can make a large notebook with all of the information requested in order, or you can put the files and documents in boxes with a label separator for each item. For instance, if item number 15 is Blind Specimens, and you don’t do them, place a sheet with number 15 on it and write “NONE.” Inspectors will simply move on to the next item.
Other items requested during an audit:
• Job description of each safety-sensitive job. I made a book with all of the safety- sensitive job descriptions. It is beter to have a book prepared, to avoid scrambling to get them all at the last minute.
• Documentation of the first time an employee performed a safety-sensitive function. Inform your Quality Assurance Department of inspection dates prior to your inspection, so they will be prepared to pull work sheets for them as requested.
• Employee application or résumé. Inspectors will compare the resume or application to your drug and alcohol history forms, to ensure you have covered the two-year record check from previous employers.
• Personnel action form, payroll record, or other document indicating the effective date of hire or transfer. Strong emphasis here—you must make sure this is very clear in your file and that no employee
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