ChesterCountyMedicineWinter2018 - 23

www.CHESTERCMS.org

required testing for five substances and substance categories, which
came to be known as the "NIDA-5": amphetamines, marijuana,
cocaine, phencyclidine, and opiates (codeine and morphine). In
October 2010, while keeping the same general five categories, they
added 6-acetylmorphine (heroin) under the "opiates" category as a
routine result rather than on-request-only; and on November 13,
2017, they expanded the opiates panel (some would say "finally")
to include the four semi-synthetic opioids, hydrocodone, oxycodone, hydromorphone, and oxymorphone, effective January 1,
2018.

ship umbrella and/or the conditions that would prompt a query
outside the MRO sphere, such as suspecting abuse and modifying
the duty status, as mentioned above. Additionally, when patients
have positive drug screens and we are unable to verify authorized
prescription use, if the testing is done under federal drug free
workplace regulations and we declare the person disqualified for
safety-sensitive duties, we also mandate very specific return to work
requirements including substance abuse counseling, repeat testing,
etc., as described above. I argued that this could represent a kind of
diagnosis and treatment that would allow us to query.

What this means is that Occupational Medicine physicians,
functioning as both certified MROs and certified DOT medical
examiners, routinely interact with opiate users (both authorized
and unauthorized), and as such have opportunities to (a) temporarily take them out of safety-sensitive jobs such as truck driving,
and (b) mandate participation in drug rehab as a condition of
employment. Additionally, since not all workplace drug testing
programs are regulated by the federal government (actually most
are not), and not all safety-sensitive jobs are within the purview
of the DOT (again, most are not), we apply these same principles
and practices wherever we are involved with interpreting drug test
results, and wherever medication use poses a potential safety risk.

Well, the PDMP didn't buy it. Here was their response:
"Occupational health physicians are not providing care to patients
when performing Medical Review Officer (MRO) services, such
as drug screening, on behalf of an employer. Per Act 191 of 2014,
prescribers may only query the PA PDMP system for patients. Accordingly, occupational health physicians are not legally permitted
to query the PA PDMP system in an MRO setting, or any other
setting in which there is not a clear patient-doctor relationship."

The only bad news in this story is that while we are required
to query the Pennsylvania Prescription Drug Monitoring Program
(PDMP) database whenever we contemplate prescribing a controlled substance in our capacities as injury care providers (same as
anyone else functioning in that kind of role), we are not permitted
to query when functioning as MROs. That's not just an assumption: I specially asked one of the PDMPs physician leaders, arguing
that based on this PDMP requirement for one of the querying
scenarios-"If a prescriber believes or has reason to believe, using
sound clinical judgment, that a patient may be abusing or diverting drugs"-since a positive drug screen always has at least the
potential to represent unauthorized use of a controlled substance,
there seems to be some logic in querying to rule that out. Also,
part of our role involves advising employers as to an employee's
fitness for duty in case even a legit prescription renders someone
relatively impaired with respect to safety sensitive jobs, such as
school bus drivers or hazardous machine operators or individuals
working at unprotected heights. We can get the information other
ways (e.g., from the treating physician and/or the dispensing pharmacy), but being able to query the PDMP represents a quicker and
more efficient way to do our jobs.
The PDMP said no, that querying as MROs fell outside the
intent of the law. I appealed that decision, telling my PDMP physician contact that I obviously had to agree that occupational physicians providing MRO services are not prescribing and treating in
the usual sense, and as such do not have typical physician-patient
relationships with the workers whose drug screens they review and
verify. However, I said I still felt that there are some parts of the
MRO function that may fall under the doctor-patient-relation-

At least I tried, and regardless we will continue doing our jobs
using old fashioned phone and fax. We will also continue being
gratified that we have steered some opiate users into rehab, gotten
others to switch to non-narcotic, non-sedating analgesics so they
could keep their jobs, and taken others off the road or out of the
factory when their medication use rendered them unsafe, whether
they had prescriptions or not. I realize these roles and functions
only address a piece of the current multi-dimensional opiate
challenge, but we feel it's a significant piece and we are proud to do
our part.

Dr. Richard Donze is the Senior Vice President for
Medical Affairs and the Director of Occupational
Medicine Services for Penn Medicine Chester County
Hospital. In his Hospital administrative role Dr. Donze
helps oversee Medical Staff-related credentialing and
works with other administrators and physician leaders
to ensure quality of care. In his Occupational Medicine
role, Dr. Donze helps direct a program that provides
business-related health services to over 1500 companies
in the Chester County region in addition to being a direct
patient care provider. Dr. Donze is board certified in
Family Medicine and Preventive/Occupational Medicine,
is also a published medical poet and essayist, and has
spoken and presented regionally and nationally on topics
in Preventive and Occupational Medicine and hospital
administration.

WINTER 2018 | CHESTER COUNT Y Medicine 23


http://www.chestercms.org/index.html

ChesterCountyMedicineWinter2018

Table of Contents for the Digital Edition of ChesterCountyMedicineWinter2018

ChesterCountyMedicineWinter2018 - 1
ChesterCountyMedicineWinter2018 - 2
ChesterCountyMedicineWinter2018 - 3
ChesterCountyMedicineWinter2018 - 4
ChesterCountyMedicineWinter2018 - 5
ChesterCountyMedicineWinter2018 - 6
ChesterCountyMedicineWinter2018 - 7
ChesterCountyMedicineWinter2018 - 8
ChesterCountyMedicineWinter2018 - 9
ChesterCountyMedicineWinter2018 - 10
ChesterCountyMedicineWinter2018 - 11
ChesterCountyMedicineWinter2018 - 12
ChesterCountyMedicineWinter2018 - 13
ChesterCountyMedicineWinter2018 - 14
ChesterCountyMedicineWinter2018 - 15
ChesterCountyMedicineWinter2018 - 16
ChesterCountyMedicineWinter2018 - 17
ChesterCountyMedicineWinter2018 - 18
ChesterCountyMedicineWinter2018 - 19
ChesterCountyMedicineWinter2018 - 20
ChesterCountyMedicineWinter2018 - 21
ChesterCountyMedicineWinter2018 - 22
ChesterCountyMedicineWinter2018 - 23
ChesterCountyMedicineWinter2018 - 24
ChesterCountyMedicineWinter2018 - 25
ChesterCountyMedicineWinter2018 - 26
ChesterCountyMedicineWinter2018 - 27
ChesterCountyMedicineWinter2018 - 28
ChesterCountyMedicineWinter2018 - 29
ChesterCountyMedicineWinter2018 - 30
ChesterCountyMedicineWinter2018 - 31
ChesterCountyMedicineWinter2018 - 32
ChesterCountyMedicineWinter2018 - 33
ChesterCountyMedicineWinter2018 - 34
ChesterCountyMedicineWinter2018 - 35
ChesterCountyMedicineWinter2018 - 36
ChesterCountyMedicineWinter2018 - 37
ChesterCountyMedicineWinter2018 - 38
ChesterCountyMedicineWinter2018 - 39
ChesterCountyMedicineWinter2018 - 40
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSummer2021
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSpring2021
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineWinter2021
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSummer2020
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSpring2020
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineWinter2020
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineFall2019
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSummer2019
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSpring2019
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineWinter2019
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineFall2018
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSUMMER2018
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineSpring2018
https://www.nxtbook.com/hoffmann/CCMSMedicine/ChesterCountyMedicineWinter2018
https://www.nxtbook.com/hoffmann/CCMSMedicine/CCMSMedicineFall2017
https://www.nxtbook.com/hoffmann/CCMSMedicine/CCMSMedicineSummer2017
https://www.nxtbook.com/hoffmann/CCMSMedicine/CCMSMedicineSpring2017
https://www.nxtbook.com/hoffmann/CCMSMedicine/CCMSMedicineWinter2017
https://www.nxtbookmedia.com