Who Can Be a Medical Review Officer for DOT Drug Tests?

Under 49 CFR 40.121, only a licensed physician (Doctor of Medicine or Osteopathy) may act as a Medical Review Officer (MRO) in the DOT drug testing program. A physician licensed in any U.S., Canadian or Mexican jurisdiction who meets the other requirements may review results for covered employees wherever they are located.

The rule requires knowledge of and clinical experience in controlled substance abuse disorders, knowledge of adulterated, substituted and invalid specimens, and current knowledge of Part 40, the DOT MRO Guidelines and the DOT agency rules for the employers served. Before performing MRO functions, the physician completes qualification training on the subjects listed in 40.121(c) and passes an examination given by a nationally recognized MRO certification board or subspecialty board. Requalification training and another examination follow during each five-year period after the first examination.

Under 40.121(e), the MRO keeps documentation showing that all requirements are currently met and provides it on request to DOT agency representatives and to employers and C/TPAs that use or are negotiating to use the MRO's services. Under 49 CFR 40.123, the MRO acts as an independent and impartial "gatekeeper" for the accuracy and integrity of the drug testing process.

How an MRO handles a laboratory result is covered in Why Does an MRO Contact an Employee after a DOT Drug Test?.

MROs are one of the provider categories in the MyDrugTesting.com directory, which can be searched by location and service.