MRO PRACTICE QUESTIONS WITH COMPLETE
SOLUTIONS!!
Official AAMRO/MROCC Medical Review Officer
Certification Practice Exam Blueprint Replica – 80 Questions
SECTION 1: DOT REGULATORY FRAMEWORK (49 CFR Part 40, DOT Agency Rules, Mandatory
Guidelines) — 18 Questions
Q1: Under 49 CFR § 40.121, which of the following is a mandatory credential requirement for an
individual to act as a Medical Review Officer in the DOT drug testing program?
A. Board certification in addiction medicine
B. Completion of a 40-hour toxicology fellowship
C. Licensed physician (Doctor of Medicine or Osteopathy) in any U.S., Canadian, or Mexican
jurisdiction
D. Active DEA registration with Schedule II prescribing authority
Correct Answer: C
Rationale: 49 CFR § 40.121(a) requires an MRO to be a licensed physician (M.D. or D.O.) in any
U.S., Canadian, or Mexican jurisdiction; licensure in one jurisdiction authorizes MRO functions
for all covered employees regardless of location. Board certification, toxicology fellowships, and
DEA registration are not statutory requirements.
Q2: An MRO receives a confirmed positive amphetamine result from an HHS-certified
laboratory. The employee presents a valid Adderall (mixed amphetamine salts) prescription for
ADHD, with pharmacy records confirming current fill within therapeutic dosing. What is the
MRO's required verification decision?
A. Verified Positive — amphetamine is a Schedule II controlled substance with no legitimate
medical use
B. Verified Negative — legitimate medical explanation exists under 49 CFR § 40.137
C. Cancelled Test — prescription stimulants are prohibited for all DOT safety-sensitive
employees
D. Refusal to Test — employee failed to disclose the prescription prior to testing
,Correct Answer: B
Rationale: 49 CFR § 40.137(a) requires the MRO to verify a confirmed positive as negative when
the employee presents a legitimate medical explanation; a current, valid prescription for
amphetamine salts used consistently with proper medical purpose constitutes such an
explanation. The MRO must verify the prescription's authenticity per § 40.141.
Q3: Which DOT agency regulates drug and alcohol testing for commercial motor vehicle
operators?
A. Federal Aviation Administration (FAA)
B. Federal Motor Carrier Safety Administration (FMCSA)
C. Federal Railroad Administration (FRA)
D. Federal Transit Administration (FTA)
Correct Answer: B
Rationale: FMCSA regulates commercial motor vehicle operators under 49 CFR Part 382, which
incorporates 49 CFR Part 40 by reference. FAA regulates aviation, FRA regulates railroads, and
FTA regulates public transit — each with mode-specific regulations referencing Part 40.
Q4: Per 49 CFR § 40.121(c), what is the minimum duration of initial MRO qualification training?
A. 4 hours
B. 8 hours
C. 12 hours
D. 40 hours
Correct Answer: C
Rationale: 49 CFR § 40.121(c) requires MRO qualification training covering collection
procedures, chain of custody, result interpretation, MRO responsibilities, and program
interaction, followed by passage of a nationally-recognized MRO certification examination. The
standard initial training course is 12 hours, with recertification every 5 years.
Q5: Under the May 2023 final rule (effective June 1, 2023), DOT authorized oral fluid testing as
an alternative to urine. As of June 2026, what is the current operational status of oral fluid
testing for DOT-regulated employers?
A. Fully implemented and mandatory for all DOT testing
B. Authorized but not yet available — no HHS-certified oral fluid laboratories exist
,C. Available only for post-accident and reasonable suspicion testing
D. Available only for FAA-regulated employers
Correct Answer: B
Rationale: While the May 2023 final rule authorized oral fluid testing under 49 CFR Part 40, as of
May 2026, no HHS-certified oral fluid laboratories are available to process DOT specimens. The
May 11, 2026 final rule (effective June 10, 2026) permits directly observed urine collections to
continue as an interim measure until oral fluid testing becomes available.
Q6: An MRO is reviewing a confirmed positive marijuana result. The employee presents a state-
issued medical marijuana card and claims legitimate medical use for chronic pain. What is the
MRO's required action?
A. Verify as negative — state medical marijuana authorization provides a legitimate medical
explanation
B. Verify as negative — chronic pain is a recognized indication for medical marijuana
C. Verify as positive — marijuana remains Schedule I under federal law with no legally valid
prescription
D. Cancel the test — jurisdictional conflict between state and federal law prevents verification
Correct Answer: C
Rationale: 49 CFR § 40.137 and § 40.151(f) establish that marijuana is a Schedule I controlled
substance with no legitimate medical use under federal law; state medical marijuana cards do
not constitute a legitimate medical explanation for DOT purposes. The MRO must verify positive
regardless of state authorization.
Q7: Under 49 CFR § 40.121(d), how frequently must an MRO complete requalification training
and examination?
A. Annually
B. Every 2 years
C. Every 3 years
D. Every 5 years
Correct Answer: D
Rationale: 49 CFR § 40.121(d) requires MRO requalification training during each five-year period
from the date of satisfactory completion of the initial certification examination, followed by
passage of a requalification examination administered by a nationally-recognized MRO
certification board.
, Q8: Which of the following substances is NOT included in the DOT 5-panel drug test under 49
CFR Part 40?
A. Oxycodone
B. Benzodiazepines
C. 6-Acetylmorphine (6-AM)
D. MDMA
Correct Answer: B
Rationale: The DOT 5-panel includes marijuana, cocaine, amphetamines (including
methamphetamine, MDMA, MDA), opiates (codeine, morphine, 6-AM, hydrocodone,
hydromorphone, oxycodone, oxymorphone), and PCP. Benzodiazepines, barbiturates,
propoxyphene, methadone, and synthetic cannabinoids are not part of the federal DOT panel.
Q9: An employer wants to add benzodiazepines to its DOT-mandated drug testing panel for
safety-sensitive employees. What is the regulatory status of this request?
A. Permitted with MRO approval and SAMHSA certification
B. Permitted if the employer conducts a separate non-DOT test
C. Prohibited — the DOT 5-panel cannot be modified
D. Permitted for pre-employment testing only
Correct Answer: C
Rationale: 49 CFR Part 40 establishes a fixed 5-panel that cannot be modified for DOT-regulated
testing. Employers may conduct separate non-DOT testing with expanded panels, but such tests
must be collected separately, documented separately, and cannot substitute for the required
DOT test.
Q10: Under 49 CFR § 40.327, what information may an MRO disclose to the employer regarding
a verified negative result where a legitimate medical explanation involved prescription
medication?
A. The specific drug name, dose, and prescribing physician
B. The drug class only (e.g., "opiates")
C. Nothing — all prescription information is protected under HIPAA
D. The medical condition being treated and expected duration of therapy
SOLUTIONS!!
Official AAMRO/MROCC Medical Review Officer
Certification Practice Exam Blueprint Replica – 80 Questions
SECTION 1: DOT REGULATORY FRAMEWORK (49 CFR Part 40, DOT Agency Rules, Mandatory
Guidelines) — 18 Questions
Q1: Under 49 CFR § 40.121, which of the following is a mandatory credential requirement for an
individual to act as a Medical Review Officer in the DOT drug testing program?
A. Board certification in addiction medicine
B. Completion of a 40-hour toxicology fellowship
C. Licensed physician (Doctor of Medicine or Osteopathy) in any U.S., Canadian, or Mexican
jurisdiction
D. Active DEA registration with Schedule II prescribing authority
Correct Answer: C
Rationale: 49 CFR § 40.121(a) requires an MRO to be a licensed physician (M.D. or D.O.) in any
U.S., Canadian, or Mexican jurisdiction; licensure in one jurisdiction authorizes MRO functions
for all covered employees regardless of location. Board certification, toxicology fellowships, and
DEA registration are not statutory requirements.
Q2: An MRO receives a confirmed positive amphetamine result from an HHS-certified
laboratory. The employee presents a valid Adderall (mixed amphetamine salts) prescription for
ADHD, with pharmacy records confirming current fill within therapeutic dosing. What is the
MRO's required verification decision?
A. Verified Positive — amphetamine is a Schedule II controlled substance with no legitimate
medical use
B. Verified Negative — legitimate medical explanation exists under 49 CFR § 40.137
C. Cancelled Test — prescription stimulants are prohibited for all DOT safety-sensitive
employees
D. Refusal to Test — employee failed to disclose the prescription prior to testing
,Correct Answer: B
Rationale: 49 CFR § 40.137(a) requires the MRO to verify a confirmed positive as negative when
the employee presents a legitimate medical explanation; a current, valid prescription for
amphetamine salts used consistently with proper medical purpose constitutes such an
explanation. The MRO must verify the prescription's authenticity per § 40.141.
Q3: Which DOT agency regulates drug and alcohol testing for commercial motor vehicle
operators?
A. Federal Aviation Administration (FAA)
B. Federal Motor Carrier Safety Administration (FMCSA)
C. Federal Railroad Administration (FRA)
D. Federal Transit Administration (FTA)
Correct Answer: B
Rationale: FMCSA regulates commercial motor vehicle operators under 49 CFR Part 382, which
incorporates 49 CFR Part 40 by reference. FAA regulates aviation, FRA regulates railroads, and
FTA regulates public transit — each with mode-specific regulations referencing Part 40.
Q4: Per 49 CFR § 40.121(c), what is the minimum duration of initial MRO qualification training?
A. 4 hours
B. 8 hours
C. 12 hours
D. 40 hours
Correct Answer: C
Rationale: 49 CFR § 40.121(c) requires MRO qualification training covering collection
procedures, chain of custody, result interpretation, MRO responsibilities, and program
interaction, followed by passage of a nationally-recognized MRO certification examination. The
standard initial training course is 12 hours, with recertification every 5 years.
Q5: Under the May 2023 final rule (effective June 1, 2023), DOT authorized oral fluid testing as
an alternative to urine. As of June 2026, what is the current operational status of oral fluid
testing for DOT-regulated employers?
A. Fully implemented and mandatory for all DOT testing
B. Authorized but not yet available — no HHS-certified oral fluid laboratories exist
,C. Available only for post-accident and reasonable suspicion testing
D. Available only for FAA-regulated employers
Correct Answer: B
Rationale: While the May 2023 final rule authorized oral fluid testing under 49 CFR Part 40, as of
May 2026, no HHS-certified oral fluid laboratories are available to process DOT specimens. The
May 11, 2026 final rule (effective June 10, 2026) permits directly observed urine collections to
continue as an interim measure until oral fluid testing becomes available.
Q6: An MRO is reviewing a confirmed positive marijuana result. The employee presents a state-
issued medical marijuana card and claims legitimate medical use for chronic pain. What is the
MRO's required action?
A. Verify as negative — state medical marijuana authorization provides a legitimate medical
explanation
B. Verify as negative — chronic pain is a recognized indication for medical marijuana
C. Verify as positive — marijuana remains Schedule I under federal law with no legally valid
prescription
D. Cancel the test — jurisdictional conflict between state and federal law prevents verification
Correct Answer: C
Rationale: 49 CFR § 40.137 and § 40.151(f) establish that marijuana is a Schedule I controlled
substance with no legitimate medical use under federal law; state medical marijuana cards do
not constitute a legitimate medical explanation for DOT purposes. The MRO must verify positive
regardless of state authorization.
Q7: Under 49 CFR § 40.121(d), how frequently must an MRO complete requalification training
and examination?
A. Annually
B. Every 2 years
C. Every 3 years
D. Every 5 years
Correct Answer: D
Rationale: 49 CFR § 40.121(d) requires MRO requalification training during each five-year period
from the date of satisfactory completion of the initial certification examination, followed by
passage of a requalification examination administered by a nationally-recognized MRO
certification board.
, Q8: Which of the following substances is NOT included in the DOT 5-panel drug test under 49
CFR Part 40?
A. Oxycodone
B. Benzodiazepines
C. 6-Acetylmorphine (6-AM)
D. MDMA
Correct Answer: B
Rationale: The DOT 5-panel includes marijuana, cocaine, amphetamines (including
methamphetamine, MDMA, MDA), opiates (codeine, morphine, 6-AM, hydrocodone,
hydromorphone, oxycodone, oxymorphone), and PCP. Benzodiazepines, barbiturates,
propoxyphene, methadone, and synthetic cannabinoids are not part of the federal DOT panel.
Q9: An employer wants to add benzodiazepines to its DOT-mandated drug testing panel for
safety-sensitive employees. What is the regulatory status of this request?
A. Permitted with MRO approval and SAMHSA certification
B. Permitted if the employer conducts a separate non-DOT test
C. Prohibited — the DOT 5-panel cannot be modified
D. Permitted for pre-employment testing only
Correct Answer: C
Rationale: 49 CFR Part 40 establishes a fixed 5-panel that cannot be modified for DOT-regulated
testing. Employers may conduct separate non-DOT testing with expanded panels, but such tests
must be collected separately, documented separately, and cannot substitute for the required
DOT test.
Q10: Under 49 CFR § 40.327, what information may an MRO disclose to the employer regarding
a verified negative result where a legitimate medical explanation involved prescription
medication?
A. The specific drug name, dose, and prescribing physician
B. The drug class only (e.g., "opiates")
C. Nothing — all prescription information is protected under HIPAA
D. The medical condition being treated and expected duration of therapy
