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Frequently Asked Question

Which Organizations Does HHS Approve to Certify Medical Review Officers?

HHS approves two organizations to certify Medical Review Officers (MROs) for federal workplace drug testing: the American Association of Medical Review Officers (AAMRO) and the Medical Review Officer Certification Council (MROCC). Both offer MRO certification through examination. HHS published this list in the Federal Register on October 23, 2026 (FR 2026-21671), with approval effective that day.

How approval works. Under Section 13.2 of the HHS Mandatory Guidelines, nationally recognized entities or subspecialty boards that seek approval to certify physicians as MROs for federal programs must submit their qualifications, a sample examination and other supporting examination materials. Approval is based on an objective review of qualifications, including the MRO applicant application form, documentation that continuing education courses are accredited by a professional organization, and the delivery method and content of the examination.

Two-year cycle. Each approved MRO certification entity must resubmit its qualifications for approval every two years. The HHS Secretary publishes a notice in the Federal Register at least every two years listing the approved entities and subspecialty boards.

Why it matters. Under Section 13.1 of the HHS guidelines, an MRO for federal agency testing is a currently licensed physician who, among other requirements, has passed an initial examination administered by an entity or subspecialty board approved by the Secretary, and who passes a requalification examination at least every five years. The October 23, 2026 notice lists the approved certifying entities and does not amend the Mandatory Guidelines. DOT has its own MRO qualification rules in 49 CFR 40.121, which require an examination administered by a nationally recognized MRO certification board or subspecialty board for medical practitioners in the field of medical review of DOT-mandated drug tests.

The FAQs on what an MRO is and what MRO stands for cover the role and DOT qualifications.

References

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