[MCOH-EH] [EXTERNAL] Re: Changing of Pre-employment Medical Evaluation and Drug Screen

hudson.warner at gmail.com hudson.warner at gmail.com
Fri Jun 24 14:44:36 PDT 2022


Agree with all of Melanie’s added comments and would also say at UC we call these exams post offer pre placement exams POPP for short.  Testing for alcohol preplacement is a legal loser. Other thing to add is to be sure to keep drug testing out of the medical record as these are not medical tests but forensic tests for the employer in this context. Warner

 

From: MCOH-EH <mcoh-eh-bounces at mylist.net> On Behalf Of Swift, Melanie D., M.D., M.P.H. via MCOH-EH
Sent: Friday, June 24, 2022 2:29 PM
To: MCOH-EH <mcoh-eh at mylist.net>
Cc: Swift, Melanie D., M.D., M.P.H. <Swift.Melanie at mayo.edu>
Subject: Re: [MCOH-EH] [EXTERNAL] Re: Changing of Pre-employment Medical Evaluation and Drug Screen

 

Adding my thoughts: 

 

Note that the ADA prohibits collecting any medical information prior to a job offer, and if they share it during the interview or hiring process, the employer must not consider it in deciding whether to offer them the job. We actually do not require new hires share their complete medical history at any point. After they’ve received an offer, they are asked to review the physical and environmental job requirements/demands, and tell us whether they have any condition that would make them unable to perform that job or if they need an accommodation. If not, then we only do an infectious disease screen. This keeps it ADA compliant. 

 

I like “post offer, preplacement” for the medical screening. As Wendy notes below they must have had an offer but not yet started; and if you include volunteers, students, or others who are not technically ”hired” then you can use the same term for everyone.

 

We use a questionnaire reviewed by a nurse for recent infectious disease exposure or symptoms of an active infectious disease, do an immunization record review, TB screening, and order any vaccines or antibody tests they may need.

 

I agree with you about eliminating alcohol testing. Alcohol is a legal substance that doesn’t require a prescription, so unless someone is on the job there’s no rule against having alcohol in your system and I wouldn’t test for it until the person is on the job, and then test for cause (plus of course return to work, followup, or random depending on any recovery support policy or DOT regulation that may apply.) 

 

You can test for other drugs before making the job offer. Usually the timing of that coincides with the background check. Then the occupational health screening happens after they’ve passed those steps and a job offer has been extended.

 

I second Wendy’s recommendation on holding all employees to the same infectious disease/immunization policy. Even if a remote worker does not formally transfer to an on-campus position later, we find that remote workers may visit campus for occasional in-person meetings or other activities, or their position may morph gradually into a hybrid or on-campus position without a formal job transfer.

Finally just a word about checking labs for immunity to vaccine preventable diseases (soapbox warning!) Check your procedures to make sure you’re only testing when necessary:

- only test for MMR if they say they have been vaccinated but there’s no vaccination record available. If you have (or can get!!!) a record of their vaccines, titers are not indicated, and if they report never being vaccinated they should just get the vaccine.

- only test for varicella immunity if they have no vaccine record available. If they’ve have only one dose, they need a second vaccine dose and not a titer.

 

Hope this helps, and good luck!

 

Melanie Swift, MD, MPH 

Sent from my iPhone





On Jun 24, 2022, at 2:14 PM, wendy thanassi <wendy.thanassi at gmail.com <mailto:wendy.thanassi at gmail.com> > wrote:

 

Hi Howard,

Thoughts for you:

 

Pre-Employment Medical Evaluation

Our illustrious Amy Behrman would call it a pre-hire physical, because they must be post-offer and pre-hire.

reviewed by an Occupational Health physician

You could consider having the comprehensive review by a physician or LIP (licensed independent practitioner/ RNP/PA) if that helps your service.

  Only selectively do a physical exam

For union/equity's sake, would be best to lay that out so everyone is treated fairly... or one could end up being perceived as treating a group differently than others (race, gender, age)... or even if you examine all people with big BMI's it could be  a problem.

Eliminate collecting vaccination titers on wholly distant/non clinical staff

I would have the same drug testing and vaccination rules for everyone (we do). People switch jobs, come in for trainings, etc. all the time. Same with vaccinations: the worst exposures Stanford had were housekeeping who went all throughout buildings, working hard, breathing heavy in rooms. I consider all HCP to be clinical, personally. Except maybe HR and fiscal :).

drug screen during their first week on campus

And I wouldn't clear them for hire until the drug test is negative.

 

But I'm, perhaps, conservative! Interested to hear what others say.

 

On Fri, Jun 24, 2022 at 10:10 AM Rudnick, Howard L <Howard.Rudnick at tuhs.temple.edu <mailto:Howard.Rudnick at tuhs.temple.edu> > wrote:

Our institution has changed in many ways since Covid in terms of using off site personnel and the critical need for personnel.  I have proposed changes in our Pre-employment medical evaluation.  I would appreciate your opinion of the suggested changes.

 

1.       Change of wording from pre-employment examination to Pre-Employment Medical Evaluation:

a.      Comprehensive medical history reviewed by an Occupational Health physician

b.      Only selectively do a physical exam

c.       Most useful information regarding decision to hire from a medical standpoint obtained from the comprehensive medical history.

2.      Eliminate collecting vaccination titers on wholly distant/non clinical staff:

a.      Process:

                                                              i.      Email sent to Occupational Health from HR

                                                            ii.      Occupational Health communicates with the Manager asking for assurance that individual will be totally off site and we communicate to them by email that they may not work in TUHS buildings.

                                                          iii.      Emails scanned into the employees Occupational Health Medical Record

                                                          iv.      Suggestions for other processes welcome

3.      Eliminate alcohol testing:

a.      Very low yield

4.      No drug and alcohol testing required for those who will wholly work from distance and not be working in TUHS buildings

5.      All applicants who live a significant distance be allowed to start work and obtain their drug screen during their first week on campus.

 

 

 

Howard L. Rudnick, MD,MHA,FACP

Clinical Professor (Adjunct), Department of Medicine

Medical Director, Occupational Health Services

Temple University Health System

Office:  (215) 707-3026

Cell:  (267) 838-7040

 

 

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The MCOH-EH List has always been moderated by members of the ACOEM Medical Center Occupational Health Section. It is currently moderated by Joe Fanucchi MD FACOEM.
List membership is free, but only subscribers may post to the list.
To post send messages to: mcoh-eh at mylist.net <mailto:mcoh-eh at mylist.net> 
To become a subscriber, or to change your subscription options (turn off email while you're on vacation, etc):   http://www.mcoh-eh.net
MediTrax / Occupational Health Systems, Inc. provides financial support to ensure the list remains a free resource for the occupational health community.
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