MRO Modifications & Change Orders 3 — Questions and Answers
Question 1: Under 49 CFR Part 40, which of the following CCF errors is considered a 'fatal flaw' that requires the MRO to cancel the test?
- Missing collection site address
- No specimen ID number on the CCF and specimen bottle seal (Correct answer)
- Collector failed to print their name
- Missing time of collection
Correct answer: No specimen ID number on the CCF and specimen bottle seal
A missing or discrepant specimen ID number between the CCF and the bottle seal is a fatal flaw that cannot be corrected and requires the MRO to cancel the test.
Question 2: An MRO receives a laboratory report showing a specimen was positive for cocaine metabolites. The employee claims the result is due to coca tea consumption. How should the MRO handle this?
- Accept the explanation and report negative
- Reject the explanation — coca tea is not a legitimate medical explanation under DOT (Correct answer)
- Request a hair follicle test to confirm cocaine use
- Cancel the test and require a supervised recollection
Correct answer: Reject the explanation — coca tea is not a legitimate medical explanation under DOT
Under DOT rules, the MRO must not accept coca tea as a legitimate medical explanation for a cocaine positive result.
Question 3: When an employer instructs the MRO to report employee testing results directly to a third-party administrator (TPA), who retains final responsibility for the MRO's decisions?
- The TPA, since they manage the program
- The employer, since they are the regulated entity
- The MRO, regardless of who receives the report (Correct answer)
- SAMHSA, as the federal oversight body
Correct answer: The MRO, regardless of who receives the report
The MRO retains full professional and regulatory responsibility for all MRO decisions, regardless of to whom the results are reported.
Question 4: A specimen arrives at the laboratory with a broken seal. What change does the laboratory make to the result before sending it to the MRO?
- The lab reports the result as positive by default
- The lab reports it as rejected for testing (Correct answer)
- The lab reports the specimen as dilute
- The lab substitutes a new specimen ID and continues testing
Correct answer: The lab reports it as rejected for testing
A specimen with a broken or missing seal is rejected for testing by the laboratory, and the MRO must then cancel the test.
Question 5: An employee tested positive for marijuana. They present the MRO with a valid state medical marijuana card. What should the MRO do?
- Verify the card and report the result as negative
- Report the result as positive — federal law supersedes state law under DOT (Correct answer)
- Defer the report until the employer reviews the card
- Cancel the test and request a urine recollection
Correct answer: Report the result as positive — federal law supersedes state law under DOT
Under DOT regulations, a state-issued medical marijuana card is not a valid medical explanation, and the MRO must report the result as positive.
Question 6: What is the MRO's responsibility when a laboratory reports a specimen as invalid due to an unidentified interfering substance?
- Report the result as negative since no drug was confirmed
- Contact the employee to determine if there is a medical explanation, then decide on cancellation or observed recollection (Correct answer)
- Automatically order a hair follicle test
- Report the result as positive for adulteration
Correct answer: Contact the employee to determine if there is a medical explanation, then decide on cancellation or observed recollection
For an invalid result, the MRO contacts the employee to see if a medical condition explains the finding and then either cancels the test or orders a direct-observation recollection.
Question 7: Under DOT Part 40, how long must the MRO keep records of verified negative results?
- 1 year (Correct answer)
- 2 years
- 5 years
- 10 years
Correct answer: 1 year
MROs must retain records of verified negative results for a minimum of 1 year.
MRO Modifications & Change Orders 3
Under 49 CFR Part 40, which of the following CCF errors is considered a 'fatal flaw' that requires the MRO to cancel the test?