2.6 Drug Testing Policy

I.    Purpose:

Some training sites require a negative drug test before the student is allowed on site. This document outlines the policies and process for a drug testing program as part of compliance for Doctor of Medicine student experiential learning.

II.   Scope and Responsibility:

The Academic, Rural and Regional Affairs Compliance Office oversees the program under the direction of the Office of Student Affairs. The Foundations Phase Offices, Clinical Departments and Regional Clinical Administration Offices may be informed of a need for a student to engage with drug testing. In conjunction with the Office of Compliance, the entities with w be responsible for communication with students and with clinical sites. The process described herein will be effective starting July 1, 2024 and applies to all students enrolled in the Doctor of Medicine program.

III.   Policies:

  1. The School of Medicine does not require routine drug testing of medical students. However, some facilities where students may participate in various curricular and co-curricular experiences do require drug testing before they accept a student. The School’s affiliation agreements with these facilities state that the testing will be done through the School rather than through the facility to protect students’ privacy.
  2. No information concerning drug testing will be shared with the facility other than to verify that the results were negative. The SOM can NOT verify drug test results from outside agencies. Clinical facilities/course numbers with drug test requirement.
  3. Students will have access to their drug test report on their MyCB account on the CastleBranch website. The School will also have access to the report via the CastleBranch website. The School will record compliance status in eValue but will not upload the reports to eValue to protect students’ privacy.
  4. A drug test result is valid for one year from initial result date and can be applied to any site requiring drug testing within the 12-months following the test date. Upon student consent, results of drug testing will be made available to the student and the School. The School of Medicine will be responsible for the cost of all drug testing for clerkship students, except in cases listed below. Foundations Phase students will be responsible for the cost of drug testing for PCP and FCM sites, as well as for various sites that may be part of other co-curricular activities at facilities requiring drug testing.
  5. Students who refuse to undergo drug testing will be referred to the Associate Dean for Student Affairs and removed from the educational setting.
  6. Students will not be allowed to begin experiential learning at a site requiring drug testing until the results of the test have been provided to the School.
  7. Students with a positive drug test result will not be allowed to start or continue their educational activity.
  8. Students who have a positive test result will be referred to the Associate Dean for Student Affairs and will also be referred to the Washington Physicians Health Program (WPHP). Students will consent to release of drug testing results by the School to the site in the event of an audit request by the site. Results will be made available to the student and to the School via the vendor’s secure web portal – MyCB account. Results will be retained in the secure web portal per the vendor’s records retention policy. The School will respond promptly to audit requests by sites for drug test results.

IV.  Procedures:

Student testing procedures

  1. Students will be informed as part of the admissions process that drug testing may be required for compliance in various educational settings. The requirement will also be noted in the student handbook and communicated to students during orientation. Communication will be made to current students on a regular basis as part of preparations for credentialing at sites that require drug testing.
  2. The School will contract with an outside vendor for drug testing.
  3. The drug test will occur prior to the student beginning an experience at the site depending on the credentialing deadlines of the educational site.
  4. The SOM will provide students with a package code for purchasing drug test via the vendor.
  5. The urine sample collection will not be directly observed by collection site personnel.
  6. The vendor will contract with a laboratory that will be used for urine drug test. The urine sample will be sent by the collection site to the laboratory for analysis.
  7. The laboratory will perform a 12-panel test for the following drugs:  *Due to federal regulations, a positive drug test is not mitigated by state law or medical marijuana authorization. The laboratory will also test the sample for temperature, specific gravity, and creatinine. All drug testing will be performed with enzyme immunoassay. All positive screens will be performed with gas chromatograph-mass spectroscopy (GCMS).
    1. Amphetamine (methamphetamine)
    2. Barbiturates
    3. Benzodiazepines
    4. Cocaine
    5. Cannabis metabolites
    6. Fentanyl
    7. MDMA/Ecstasy
    8. Methadone
    9. Methaqualone
    10. Opiates (codeine & morphine)
    11. Phencyclidine
    12. Oxycodone
  8. All drug tests with non-negative results will be reviewed by the vendor’s Medical Review Officer (MRO). The MRO will contact the student to discuss the result and investigate medically plausible explanations of non-negative results. If the MRO determines that there is no medically plausible explanation for the non-negative result or sufficient evidence of tampering (e.g., temperature inconsistent with just-voided urine), the result will be reported as positive. Once the MRO review is complete (if needed), the vendor will provide the results of the drug test to the student and to the School through the vendor’s secure web portal. The reported result will either be “negative” or “positive.”
  9. Dilute results: Students are advised not to drink a lot of water or other liquids in the short period prior to testing. Doing so can produce a diluted specimen. If the laboratory returns a result such as “diluted specimen,” the student will be required to submit another order and provide a new specimen within 24 hours. Costs associated with repeat drug testing for dilute results are the student’s responsibility.
  10. If the laboratory returns a positive result that a designated MRO has labeled as consistent with ingestion of a food substance, the student will be required to repeat drug testing between 72 hours and 120 hours after initial testing. Costs associated with repeat drug testing for “consistent with ingestion of a food substance” results are the student’s responsibility.
  11. The SOM Compliance team will review all results of drug testing upon receipt from the vendor.
  12. If a site refuses to accept the School’s process for compliance in drug testing, students consenting to placement at those sites will need to complete additional testing as stipulated by the site.

Steps if positive results

  1. Students with a positive result will be referred to the Associate Dean for Student Affairs and the Washington Physician’s Health Program (WPHP) and must receive clearance from WPHP and repeat and pass drug testing prior to returning to the educational setting.
  2. In accordance with the School’s Substance Use Policy, a student who is determined by assessment through WPHP to have a diagnosis of “Substance Use Disorder” shall be required to participate in WPHP and sign a WPHP Monitoring Agreement. The WPHP agreement requires, among other things, regular, random, on-demand, toxicology testing. Abstinence from the use of unauthorized substances, as demonstrated through negative toxicology testing, is a condition of compliance with the monitoring agreement. WPHP will inform the School if a student fails to maintain compliance with a WPHP monitoring agreement and fails to follow recommendations to remedy a compliance deficiency. Failure to maintain clearance from WPHP will result in removal of the student from the educational setting.

Audit requests from sites

  1. Upon receipt of a request for compliance audit, SOM compliance staff will provide evidence of compliance to the requesting site within two business days.
  2. If there is any actual or anticipated impediment to fulfilling a request for evidence of compliance within the two business-day time frame, the site will be contacted as early as possible, and the situation explained. SOM compliance staff will, in such a circumstance, provide a reasonable time frame for when the evidence can be delivered to the requesting site.

V.    Annual Timeline:

July

  • Foundations Phase staff will communicate the SOM drug testing policy to incoming MS1 students during orientation.
  • Foundations Phase staff will remind MS2 students of the drug testing policy in July.

February

  • Compliance staff will update stakeholders with any changes to drug testing requirements.
  • Compliance staff will confirm with the vendor any changes to pricing and procedures.

March

  • Compliance staff will identify students in the Patient Care and Explore and Focus Phases needing to complete a drug test in the coming academic year.
  • Compliance staff and clerkship staff will communicate specific drug testing requirements and timing to MS2, MS3 and MS4 students in the Patient Care and Explore and Focus Phases. MS2, MS3 and MS4 students who must complete drug testing as part of the credentialing process for their clerkship site will receive a monthly reminder email from Compliance staff until the requirement is completed.
  • Compliance staff will inform MS2 students of the drug testing policy as part of Transition to Clerkships course in March.

NOTE: Changes in placements that occur may result in modified drug testing requirements that need to be communicated outside of this timeline.

  • Policy Owner: Vice Dean for Academic, Rural & Regional Affairs Authorized Governing Body: Faculty Council on Academic Affairs (FCAA)
  • Policy Category: General Policies and Requirements Last Approved Date: June 2024  Effective Date: July 1, 2024 Next Review Date: June 2028
  • Policy Contact: UW School of Medicine, Compliance Office, lbellis@uw.edu, Education Quality Improvement Office, eqi@uw.edu
  • Webpage last updated: August 22, 2024