Section 40.141 Question and Answers

40.141                                                                       07/06

QUESTION:

Is a Medical Review Officer (MRO) permitted to accept an employee’s prescription for medication obtained over the Internet?

ANSWER:

  • An MRO is authorized to accept an employee’s prescription for medication obtained over the Internet only if there is proof that a legitimate doctor-patient relationship had been established.

  • The following four elements generally serve as an indication that a legitimate doctor-patient relationship has been established:

    -- A patient has a medical complaint;

    -- A medical history has been taken;

    -- A physical examination has been performed; and

    -- Some logical connection exists between the complaint, the medical history, the physical examination, and the drug prescribed.

  • Standing alone, the completion of an online questionnaire reviewed later by a pharmacy-employed doctor fails to establish a proper doctor-patient relationship.

  • The MRO should, at a minimum, consider the following items when verifying the test result:

    -- The name, physical location, and state(s) of licensure of the prescribing practitioner;

    -- Whether the employee was professionally evaluated for the current medical complaint by the prescribing practitioner, and the last time the employee was in direct contact with the prescribing practitioner;

    -- Whether the employee initiated the request to the pharmacy for a particular medication; and

    -- Whether a proper doctor-patient relationship existed.

  • It is the employee’s responsibility to provide sufficient documentation to address MRO inquiries as to whether there was a legitimate doctor-patient relationship.

 

This information was copied from a federal government resource. Always verify the accuracy of this information against the most recent version of the Code of Federal Regulations: https://www.ecfr.gov/current/title-49/subtitle-A/part-40 or the Office of Drug & Alcohol Policy & Compliance: https://www.transportation.gov/odapc.

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