Lab Test Results by Any Other Name
Throwing Down the Gauntlet in Support of Michael Langan, M.D.
A Three Part Expose’
Anne Phelan-Adams, M.D.
Dr. Michael Langan of Massachusetts came to “The Talbott Center” in College Park, Georgia with an exemplary record as a physician. In his thirteen years at Harvard Medical School and ten years at Massachusetts General Hospital (MGH), Langan was never professionally disciplined or threatened with a malpractice claim. He was highly regarded by his peers and patients. Yet, Langan was discharged from Talbott, with diagnoses of alcohol dependence, absent supporting history or evidence of withdrawal, and cognitive as well as psychological dysfunction. He knew that the diagnoses were spurious, but Dr. Langan also knew to continue practicing medicine he would have to agree to whatever conditions imposed upon him as an alleged “impaired physician” by Physician Health Services, Inc. (PHS).
PHS is a Massachusetts-based, nonprofit Physician Health Program (PHP) and affiliate of Massachusetts’ physician disciplinary agency, the Massachusetts Board of Registration in Medicine (BORIM). In 2008, Dr. Langan reluctantly signed a five-year letter of agreement with PHS, stipulating that he completely abstain from alcohol and any other substances of potential abuse, take naltrexone to help prevent relapse, and submit to frequent random drug and alcohol testing. On occasion, Langan’s urine tested positive for an alcohol metabolite, ethyl glucuronide, which was attributed to use of his asthma inhalers and/or the alcohol-based hand sanitizers required by MGH. Langan’s hair analysis in June 2008 showed a positive screen for metabolites of hydrocodone attributed to his remote use of Vicodin® for shingles pain. Otherwise, Dr. Langan reports assiduously complying with his PHS contract and practicing medicine over the next three years, without interference.
PHS trouble decidedly reared its head for Dr. Langan when the United States Drug Testing Lab (USDTL) reported a July 1, 2011 PEth (Phosphatidylethanol) blood test, positive at 365.4 ng/ml, a level indicating heavy, long term alcohol consumption. Langan attests that he did not consume alcohol in the three years since signing his 2008 PHS contract. Nonetheless, PHS proceeded as if USDTL’s test results were correct. Its Director, medical doctor Luis Sanchez, demanded that, within 14 days of his notice, Dr. Langan arrange for an extensive evaluation at an out-of-state “board-approved” substance abuse assessment center, along with a large upfront payment of fees.
Concerned about the potential bias and financial conflicts of interest attributable to “PHS-approved” assessment centers, Dr. Langan immediately arranged for a comprehensive independent evaluation for alcohol abuse with both the Chief of Addiction Psychiatry and a board-certified addiction medicine specialist internist at MGH. The evaluations included collateral information from his attending physicians and MGH supervisors, a complete physical examination, and a battery of lab tests for alcohol use and abuse as well as their potential sequelae.
Both MGH’s Chief of Addiction Psychiatry and the hospital’s aforementioned substance abuse specialist concluded that Dr. Langan had no evidence of alcohol abuse, and they assured the PHS his professional comportment, patient care, diagnostic acumen and teaching skills were “superlative”. The PHS refused to accept these conclusions. At its insistence, Dr. Langan went to the Hazelden Addiction Treatment Center in Minnesota for a four-day substance abuse evaluation starting September 18, 2011. He had no withdrawal symptoms or other signs of substance use disorder and was discharged with notation that he was in sustained remission from opioid dependence and showed no evidence of alcohol dependence.
While at Hazelden, Dr. Langan’s blood PEth and urine ETG tests were repeated, plus hair and fingernail samples were tested. The results showed no evidence of alcohol consumption either at the time of his admission or within the previous six months, and he had no symptoms of withdrawal. The Hazelton evaluators concluded Dr. Langan had no past or present alcohol problem, but because they could not explain the positive PEth of July 2011 attributed to him, violation of his abstinence agreement with PHS was not ruled out.
After months of denying or seemingly ignoring Dr. Langan’s requests for information about its aberrant test result attributed to him, USDTL finally provided Langan what is called a “litigation packet” on December 12, 2011. Such packets are sets of forensic documents noting errors, if any, in disputed collection, testing, validation, and reporting processes, compiled in response to related, formal complaints. The USDTL/Langan litigation packet evidences that a collection date for the corresponding chain-of-custody form (CCF) was initially missing, and, at first, the form’s unique donor identification number did not match Dr. Langan’s identification number. Instead of the errors prompting immediate cancellation of the test results at issue, it appears that on July 19, 2011, PHS Director of Operations Linda Bresnahan, essentially asked USDTL to “update” the related CCF to include a July 1, 2011 collection date as well as Dr. Langan’s Donor ID picture and number. A copy of a FAX request that USDTL “(p)lease update the lab report to reflect that chain of custody was maintained” was included in the USDTL/Langan litigation packet.
With regard to both the original and “updated” CCF, Joseph Jones, USDTL’s Vice President of Laboratory Operations, certified that the subject specimen was “examined upon receipt, handled and analyzed in accordance with (the) laboratory’s Standard Operating Procedure.” Apparently by letter of July 28, 2011, PHS Director Luis Sanchez advanced the contention to attorney Robert Harvey of BORIM’s “Physician Health & Compliance” division that Dr. Langan was an alcoholic who violated the terms of its agreement with him. To continue practicing medicine, Langan signed a new agreement extending his PHS contract for another two years, stipulating he attend three AA meetings per week, and requiring that he submit to PHS signed proof of attending those meetings.
Still convinced his purported July 1st PEth Blood Test was fabricated, Dr. Langan sought help in confirming that belief from an investigator with the College of American Pathologists (CAP) in January 2012. According to Langan, he did not learn until the investigator told him by phone in December 2012, that the test was invalidated on October 4, 2012. What appears to be a report from Joseph Jones, USDTL’s Vice President of Laboratory Operations, to PHS Director Luis Sanchez, dated October 4, 2012, indicates as much. However, it seems by an October 23, 2012 letter, Sanchez reported to attorney Harvey of BORIM’s Physician Health & Compliance only that Langan “repeatedly represented to PHS that he participated in required peer support group meetings that he did not, in fact, attend.”
On December 11, 2012, reportedly the next day after an inquiry from Dr. Langan, PHS Director Sanchez advised attorney Harvey by letter that on “December 10, 2012, Physician Health Services (PHS) received a revision to a laboratory test result for Dr. Michael Langan from a blood sample which he provided on July 1, 2011, which . . . indicates that the ‘external chain of custody protocol [for that sample] was not followed per standard protocol’.” Already Harvey was pursuing disciplinary action against Langan per Sanchez’s October 23, 2012 letter complaining of Langan missing meetings required due to that invalidated laboratory test result. According to Dr. Langan, Sanchez has never acknowledged knowing of the invalidation before December 10, 2012. He merely quips in his December 11th, 2012 correspondence to Harvey, “PHS did not make a determination of relapse following that positive test, nor is PHS aware of any action taken by the Massachusetts Board of Registration in Medicine . . . as a result of the July 28, 2011 report” which “PHS will continue to disregard”.
 These requirements compelled Dr. Langan to submit to PHS the names of other AA attendees who could corroborate his meeting attendance despite their expected anonymity. Also, Langan had to cease using his hospital-required hand sanitizers despite the deleterious effect on his health, and discontinue the two asthma inhalers that reportedly controlled his severe asthma for over a decade.