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Medical Eligibility Requirements

Attachment 4: Role of Agency Medical Review Officer

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The role of the agency Medical Review Officer (MRO) is to provide a mechanism for uniformly and consistently applying medical decisions and policies. Generally, agency MRO’s are either board certified in the field of occupational medicine or their practice is limited to the field of occupational medicine. The MRO can provide the following advisory and consultative services:

• Current and complete medical/technical information regarding specific medical/physical conditions or medical examination procedures relevant to existing or proposed physical requirements or health-related personnel management programs for agency employees.
• Technical assistance includes advisory opinions in medical and occupational health areas (i.e., worker’s compensation; disability retirement; medical standards; EEOC cases; civil lawsuits, Merit System Protection Board challenges) to ensure compliance with agency policy.
• Expert review and analysis of medical documentation and other materials submitted by an agency in support of:
  1. Medical/physical disqualifications of applicants;
  2. Employees’ restoration rights under 5 U.S.C. 8151 following full or partial recovery from compensable on-the-job injuries; and
  3. Requests for job accommodations or other special benefits related to accommodation documented health conditions.
• Written reports on medical standards, medical policy issues, or individual medical documentation reviews as requested.
• Guidance for resolving complex medical/personnel management issues where there are no established guidelines or precedents, including, but not limited to the following:
  1. Advisory opinions clarifying medical/psychiatric issues on the continued eligibility for access to classified information of Federal employees who hold top security clearances.
  2. Guidance regarding new and experimental procedures relating to such issues as vision correction procedures, surgical implants, or prosthetic devices, as a means of satisfying medical or physical qualification requirements.
  3. Reports to condense findings, analyses, conclusions/recommendations agencies can use to fulfill complex managerial responsibilities related to the medical evaluation and clearance process of the respective agency.
  4. Research and analyze complex legal and medical issues through coordination with the Office of the General Counsel of the respective agency.
  5. Research and analyze technical, scientific and medical data in support of agency policy development and program management.

MRO review of medical documentation would consist of an impartial and comprehensive evaluation to ensure: (1) the diagnosis or clinical impression is justified in accordance with established diagnostic criteria; and (2) the conclusions and recommendations are consistent with the generally accepted medical/safety principles and practice.

Agencies may routinely consult with the MRO when a pre-placement medical evaluation raises a significant health or safety concern that the medical condition of the applicant may adversely affect safe and efficient job performance. The MRO may take a detailed occupational and environmental history and conduct a comprehensive work-site assessment. The MRO may coordinate medical review efforts with industrial hygienists, industrial audiologists, safety officers, occupational health nurses, and agency training personnel and supervisors. A multi-faceted approach to medical evaluations (medical, safety, and personnel) is beneficial to facilitate the compilation of data on the nature and extent of the applicant’s medical condition and its impact on job performance.

Prior to formulating a conclusion on an applicant’s health status and recommending any job restrictions and limitations, the MRO should:

• Document the degree of the applicant’s impairment;
• Evaluate the seriousness of the applicant’s medical condition(s);
• Identify any medication requirements;
• Identify and learn the specific tasks (essential functions) that the applicant would need to perform the work of the position;
• Identify environmental, industrial, and occupational conditions under which the job tasks or essential functions would be required to be performed; and
• Consider whether these job duties and conditions of employment will aggravate, accelerate, exacerbate, or permanently worsen the applicant’s condition(s).

Common mistakes on the part of examining physicians (non-occupational medical specialists) can include: clearing an applicant for unrestricted employment before learning enough about ongoing exposures, potential job duties/tasks, conditions of employment; and failure to provide sufficient information to the applicant to aid him or her in defining meaningful work restrictions or other forms of reasonable accommodation.