ODAPC Updates
What Medical Examiners Need to Know: DOT Drug & Alcohol Updates from ODAPC - February 2026
Stay current. Stay compliant. Stay certified.
If you're a certified Medical Examiner - or preparing for your NRCME initial certification or 10-year recertification exam - staying up to date on federal regulatory changes is not optional. It's a core competency tested on the exam and required for compliant practice. The U.S. DOT's Office of Drug and Alcohol Policy and Compliance (ODAPC) recently released several important updates that every CME should be aware of.
Below, the NRCME Training Institute breaks down the key updates - and explains why they matter for your practice and your certification.
1. The DOT Employer Handbook Has Been Revised - First Time in 10 Years
ODAPC has released a major update to its publication, What Employers Need to Know About DOT Drug and Alcohol Testing: Guidance and Best Practices. This is the first revision in a decade, and it clarifies several critical points that intersect with the work of Medical Examiners.
Key changes include:
• Clarification that supervisors and service agents must distinguish between DOT and non-DOT testing forms
• Confirmation that owner-operators are not required to have supervisor reasonable-suspicion training
• Clarification that service agents do not make collection-site refusal determinations
• Updated DER (Designated Employer Representative) responsibilities related to employee refusals
Why it matters for Medical Examiners: Understanding the boundaries of each party's role in the DOT drug and alcohol testing process - and how those roles differ from medical review - is foundational knowledge for your NRCME exam. The distinction between DOT and non-DOT processes is a frequently tested concept.
2. Marijuana Rescheduling: What It Does (and Doesn't) Change for CMEs Right Now
On December 18, 2025, a Presidential Executive Order directed the Department of Justice to begin the process of rescheduling marijuana from Schedule I to Schedule III. This has generated significant confusion in the transportation and occupational health communities.
Here is the bottom line: Nothing has changed yet.
ODAPC has been explicit - marijuana remains a Schedule I controlled substance until the formal rescheduling process is complete. For DOT-regulated safety-sensitive positions (including commercial motor vehicle drivers), marijuana use is still prohibited. Labs, Medical Review Officers (MROs), and Substance Abuse Professionals (SAPs) must continue to follow 49 CFR Part 40 as written.
DOT's existing guidance on medical marijuana, recreational marijuana, and CBD products remains fully in effect.
Why it matters for Medical Examiners: You will encounter drivers who believe marijuana is now permissible because of the Executive Order. As a CME, you need to confidently counsel drivers and document accordingly. Expect questions about marijuana policy, MRO responsibilities, and 49 CFR Part 40 to appear on both the initial and 10-year recertification NRCME exams.
3. MROs and SAPs: ODAPC Subscription Is a Regulatory Requirement
Per 49 CFR §§ 40.121(b)(3) and 40.281(b)(3), Medical Review Officers and Substance Abuse Professionals are required by regulation to subscribe to ODAPC email updates. This is not a suggestion - it is a compliance obligation.
If you serve as an MRO in addition to your role as a CME, verify that you are subscribed at transportation.gov/odapc/get-odapc-email-updates. Employers of CDL drivers are also strongly encouraged to subscribe.
Why it matters for Medical Examiners: Regulatory compliance and awareness of DOT's communication infrastructure is part of the CME knowledge base. Questions about the regulatory responsibilities of MROs and other stakeholders frequently appear on the NRCME exam.
Preparing for Your NRCME Exam? Know the Regs. Pass the First Time.
Updates like these are exactly why exam preparation needs to go beyond memorizing physical exam standards. The NRCME exam tests your understanding of the entire regulatory environment in which you operate - including DOT drug and alcohol policy, MRO roles, FMCSA regulations, and your obligations under 49 CFR Part 391.
At the NRCME Training Institute, our curriculum is continuously updated to reflect the latest regulatory changes. That's one reason our students achieve a 99% pass rate on the NRCME certification exam.
And if you don't pass? Our Exam Pass Guarantee has you covered. We stand behind our training because we know it works.
Ready to Get Certified or Recertified?
Whether you're a physician, chiropractor, PA, NP, or DO pursuing your initial NRCME certification or completing your required 10-year recertification, the NRCME Training Institute offers flexible, comprehensive training designed to get you exam-ready, and keep you compliant in a constantly evolving regulatory landscape.
Join thousands of certified Medical Examiners who trusted NRCME Training Institute to prepare them for success.