Ask X3What does 49 CFR 40.121 (Who is qualified to act as an MRO?) require?
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As Ask X3, your fleet-compliance assistant, here is what is required to act as a Medical Review Officer (MRO) under 49 CFR 40.121:
To be qualified, an MRO must meet the following requirements before performing any MRO functions:
1. Credentials:
* Must be a licensed physician (Doctor of Medicine or Osteopathy) in any U.S., Canadian, or Mexican jurisdiction. A license in just one of these jurisdictions allows you to review results for covered employees anywhere they are located, without needing licenses in other states or provinces.
2. Basic Knowledge:
* Must have clinical experience and knowledge in controlled substances abuse disorders, including alternative medical explanations for confirmed lab results.
* Must understand adulterated, substituted, and invalid specimens and their possible medical causes.
* Must know the rules in 49 CFR Part 40, the DOT MRO Guidelines, and applicable DOT agency regulations, keeping current on all changes. You must also subscribe to the ODAPC email list-serve.
3. Qualification Training and Examination:
* Must complete qualification training covering collection procedures, chain of custody, reporting, recordkeeping, interpreting test results, MRO roles and responsibilities, interactions with program participants (like DERs and SAPs), and applicable rules and policies.
* Must pass a comprehensive examination administered by a nationally-recognized MRO certification board or subspecialty board.
4. Requalification Training:
* Must complete requalification training and pass another exam from a nationally-recognized MRO board every five years.
5. Documentation:
* Must maintain and provide documentation proving you meet all these requirements upon request to DOT representatives, employers, and C/TPAs using or considering your services.