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The medical review officer’s (MRO’s) primary responsibility is to review and interpret positive drug test results obtained from the certified laboratory. The MRO serves a key role in the final determination of the results of drug testing conducted under the Federal Motor Carrier Safety Regulations (FMCSRs).
These requirements apply to MROs involved in the drug testing process as it relates to drivers of commercial motor vehicles (CMVs) in interstate, intrastate, and foreign commerce.
The MRO acts as an independent and impartial “gatekeeper.” The MRO is an advocate for the accuracy and integrity of the drug testing process.
The MRO’s duties include:
An MRO’s medical review of a driver’s drug test results does not constitute an established doctor-patient relationship.
The MRO may not enter into any relationship with a motor carrier’s laboratory that creates a conflict of interest or the appearance of a conflict of interest. An MRO may not derive any financial benefit by having a motor carrier use a specific laboratory.
Basic knowledge. An MRO must be knowledgeable about:
The MRO must subscribe to the Office of Drug and Alcohol Policy and Compliance’s (ODAPC) listserve.
Qualification training. Qualification training must provide instruction on the following subjects:
Following completion of the qualification training, the MRO must satisfactorily complete an examination administered by a nationally-recognized MRO certification board or subspecialty board for medical practitioners in the field of medical review of DOT-mandated drug tests.
Requalification training. During the five-year period from the date on which the MRO successfully completed the exam previously mentioned, the MRO must complete requalification training. The requalification training must meet the same requirements as the qualification training previously mentioned.
Following completion of the requalification training, the MRO must complete an examination administered by a nationally recognized MRO-certification board or subspecialty board for medical practitioners in the field of medical review of DOT-mandated drug tests. The exam must cover all the elements of the qualification training previously mentioned.
Record retention. The MRO must maintain documentation showing they currently meet all of the training requirements. This information must be provided on request to DOT agency representatives and to employers and C/TPAs who are negotiating to use the MRO’s services.