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🩺 Practice Brief: Medical Evaluation of Shy Bladder Cases in Drug Testing

Shy bladder scenarios—where an individual is unable to provide a sufficient urine sample during a drug test—can pose significant clinical, regulatory, and operational challenges. Mishandling them may lead to non-compliance with federal regulations, miscommunication with employers, or improper designation of a refusal to test.

This NAOHP Practice Brief provides a detailed overview of the proper clinical response, evaluation protocols, and reporting requirements associated with shy bladder cases, particularly within DOT and safety-sensitive settings.

🔹 Clinical Procedures & Time Tracking Understand how to properly document and manage the shy bladder collection process within the 3-hour window, including required fluid intake, observed collections, and collection site responsibilities.

🔹 Medical Evaluation Requirements Clarify when and how to refer an employee for a medical evaluation following an unsuccessful collection attempt—and what type of clinician is eligible to conduct that evaluation under DOT rules.

🔹 Valid vs. Invalid Medical Explanations Distinguish between acceptable physiological and psychological conditions versus non-qualifying factors like situational anxiety or simple dehydration.

🔹 Structured Referral & Reporting Practices Review recommended language and content to include in referrals to outside physicians and learn how MROs should receive and interpret findings from the evaluator.

🔹 Employer Communication & Legal Considerations Get guidance on how to document and share results appropriately with employers—particularly when safety-sensitive work or a refusal-to-test determination is involved.

Who Should Read This Brief?

• Medical Review Officers (MROs)

• Occupational Medicine Providers and Clinic Directors

• Employer Services Coordinators

• Compliance and Risk Managers

• Collection Site Supervisors

📚 A Practical Reference for Real-World Compliance

This brief consolidates key procedures from DOT 49 CFR §40.193, MROCC and AAMRO best practices, and lessons from experienced clinicians managing shy bladder scenarios in the field.

This Practice Brief is available to NAOHP members and subscribers.

If you're not a member yet, consider joining for access to this and dozens of other compliance and clinical operations resources.

👉 Access the Brief

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You’ll also receive access to our upcoming Practice Brief on Drug Testing Protocols, and future updates from NAOHP’s newsletter and MRO and Compliance Resource Center.

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