Support Center

A Medical Review Officer (MRO) is a licensed physician who reviews and interprets drug test results before they reach the employer (49 CFR 40.121). A laboratory result is not final until the MRO has reviewed it.

Why it matters

The MRO is the independent medical gatekeeper of the DOT drug testing process. Before a laboratory-confirmed non-negative result is reported as verified, the MRO gives the employee the chance to discuss it and considers whether there is a legitimate medical explanation (49 CFR 40.129). The employer acts on the verified result the MRO reports, not on the raw laboratory result.

What the MRO does

• Reviews the custody and control form (CCF) and the laboratory result for each test.
• Reviews negative results; staff under the MRO's direct, personal supervision may handle the administrative review, and the MRO personally re-reviews a sample each quarter (49 CFR 40.127).
• Interviews the employee and verifies laboratory-confirmed positive, adulterated, substituted, or invalid results (49 CFR 40.129 to 40.159).
• Tells the employee about the right to have the split specimen tested (49 CFR 40.153).
• Reports verified results to the employer's DER (49 CFR 40.163 to 40.167).
• For FMCSA-regulated drivers, reports certain violations to the Clearinghouse.

Clearinghouse reporting

MROs must report the following to the FMCSA Clearinghouse within 2 business days of making the verification or determination (49 CFR 382.705(a)):

• verified positive, adulterated, or substituted controlled substances test results;
• refusal-to-test determinations for controlled substances tests.

Any change to a reported result must be reported within 1 business day of making the change. Each report includes:

• the reason for the test;
• the Federal Drug Testing Custody and Control Form (CCF) specimen ID number;
• the driver's name, date of birth, and CDL number and state of issuance (a Social Security number or employee identification number may not be used);
• the employer's name, address, and USDOT number, if applicable;
• the date of the test and the date of the verified result;
• the test result.

How Med-Stop supports MROs

Med-Stop MRO can automate the required Clearinghouse reporting. To enable it:

1. Register as an MRO in the FMCSA Clearinghouse: Clearinghouse registration.
2. Invite the Med-Stop MRO assistant to be your Clearinghouse MRO assistant by sending the invitation to mroassistant@med-stop.com.
3. Med-Stop then completes the MRO assistant setup on your MRO user record.