2026/2027 | MRO Medical Review Officer
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Section 1: DOT Regulations (49 CFR Part 40)
Q1: Under 49 CFR Part 40, what is the MRO's timeframe for reporting a verified positive, adulterated, or
substituted test result to the Designated Employer Representative (DER)?
A. Immediately upon verification.
B. Within 24 hours of the donor interview.
C. Within 2 business days of the verification. [CORRECT]
D. Within 5 business days of receiving the result from the lab.
Correct Answer: C
Rationale: 49 CFR 40.163(b) states that the MRO must report verified results (positive, adulterated,
substituted, or refusals) to the DER within two business days. Immediate reporting is not required, but
prompt reporting is mandated to ensure the employer can take necessary safety actions.
Q2: Which of the following drug classes is NOT part of the standard DOT 5-panel drug testing panel?
A. Marijuana (THC)
B. Cocaine
C. Benzodiazepines [CORRECT]
D. Phencyclidine (PCP)
Correct Answer: C
,Rationale: The standard DOT panel (49 CFR 40.85) includes Marijuana, Cocaine, Amphetamines, Opiates,
and PCP. Benzodiazepines are not included in the federal testing panel, though they may be tested for in
non-DOT or specific agency panels (like the Federal Railroad Administration's extended panel).
Q3: A donor provides a urine specimen that is outside the normal temperature range (e.g., 88°F). What
is the immediate next step according to 49 CFR Part 40?
A. The collector rejects the specimen and sends the donor home.
B. The collector must obtain a new specimen under direct observation. [CORRECT]
C. The collector discards the specimen and allows the donor to try again later.
D. The collector labels it as "Invalid" and ships it to the lab.
Correct Answer: B
Rationale: Per 49 CFR 40.43, if the specimen temperature is out of range (90°F–100°F), it is a "shy
bladder" or temperature issue situation requiring a new collection. However, specifically, if the
temperature is out of range, the collector must immediately collect a second specimen under direct
observation (monitored) procedures to detect potential substitution or adulteration.
Q4: When a laboratory reports a specimen as "Invalid" and the MRO determines there is no medical
explanation for the invalidity, the MRO must:
A. Report the result as "Negative" to the DER.
B. Report the result as "Refusal to Test" to the DER.
C. Cancel the test and require the donor to submit to a re-collection immediately under direct
observation. [CORRECT]
D. Cancel the test and allow the employer to decide on re-testing.
Correct Answer: C
Rationale: According to 49 CFR 40.164, if an MRO verifies an invalid result (no medical explanation) or
the lab reports a specimen that meets the criteria for direct observation re-collection (e.g., invalid
result), the MRO cancels the test and directs the agency to require a re-collection under direct
observation. It is not a refusal until the donor refuses that second test.
,Q5: An MRO receives a confirmed positive result for Methamphetamine. The donor admits to using
methamphetamine but claims it was for a medical procedure years ago. How should the MRO proceed?
A. Verify the result as Negative if the donor seems honest.
B. Verify the result as Positive because illicit use was admitted. [CORRECT]
C. Cancel the test.
D. Report it as "Refusal to Test."
Correct Answer: B
Rationale: If a donor admits to the use of an illicit substance (non-prescribed), the MRO must verify the
test as positive. The MRO does not have discretion to overturn a positive result based on a donor's claim
of legality or past medical use if there is no valid current prescription or legal justification (49 CFR
40.137).
Q6: What constitutes a "Refusal to Test" under DOT regulations if the donor behaves disruptively during
the collection?
A. The donor asks to wash their hands before providing the specimen.
B. The donor refuses to remove a hat or outer garment.
C. The donor engages in conduct that clearly obstructs the testing process, and the collector stops the
collection. [CORRECT]
D. The donor provides a specimen that is slightly below the minimum volume.
Correct Answer: C
Rationale: 49 CFR 40.191 outlines "refusal to test." Engaging in conduct that clearly obstructs the
process (e.g., verbal abuse, threatening the collector, leaving the site) is a refusal. Refusing to remove a
hat is generally not a refusal unless it conceals adulterants, but obstructive behavior is. (Actually,
refusing to remove outer garments can be a refusal if requested for the inspection, but option C is the
broader, more definitive description of obstructive conduct).
Q7: For a Federal employee, the laboratory must report a confirmed positive for Marijuana if the
confirmatory concentration of delta-9-tetrahydrocannabinol (THC) is at or above:
A. 15 ng/mL [CORRECT]
B. 50 ng/mL
, C. 20 ng/mL
D. 100 ng/mL
Correct Answer: A
Rationale: The confirmation cutoff for Marijuana (THC) is 15 ng/mL. The initial screening cutoff is 50
ng/mL. The MRO must know the confirmatory cutoffs to interpret lab reports accurately (49 CFR 40.87).
Q8: Under what circumstance is an MRO permitted to disclose a donor's medical information to a third
party without the donor's written consent?
A. Only to the employer's HR department.
B. To the Substance Abuse Professional (SAP) as part of the return-to-duty process.
C. To the Medical Review Officer's medical consultant for consultation purposes. [CORRECT]
D. Never; written consent is always required.
Correct Answer: C
Rationale: 49 CFR 40.163 allows the MRO to disclose medical information to an MRO staff member or
consultant (e.g., a toxicologist) necessary to perform the MRO functions. Disclosure to the SAP usually
requires consent (though the MRO report initiates the SAP process). Disclosure to the employer is
strictly limited to the result (Negative/Positive/Refusal), not the medical data.
Q9: If a donor cannot provide a sufficient amount of urine (Shy Bladder), the collector must begin the
"shy bladder" procedure. This includes:
A. Allowing the donor to leave and return within 24 hours.
B. Keeping the donor at the collection site and encouraging them to drink up to 40 ounces of fluid.
[CORRECT]
C. Sending the donor for a blood test immediately.
D. Collecting an oral fluid specimen instead.
Correct Answer: B
Rationale: 49 CFR 40.193(b) requires the collector to instruct the donor to drink up to 40 ounces of fluids
(not necessarily all at once) and remain at the site for up to three hours to try to provide a specimen.