What to Know About SAP Return to Duty & Follow Up Testing After Your SAP Assessment is Completed

FMCSA Clearinghouse Step 4, Step 5, and Beyond
Feb 12, 2025 by Brian T. Davis LISW, SAP

DOT SAP Trucking

SAP Return to Duty & Follow-Up Drug Testing Tips for DOT-Regulated Employees

Introduction

Every week, we receive calls from commercial drivers who completed their DOT SAP assessment weeks, months, or even years ago but need clarification about SAP return to duty testing or follow-up testing requirements. Many drivers assume that after completing their SAP assessment and Step 5 on the FMCSA Clearinghouse, the process is over. Unfortunately, this misunderstanding can lead to compliance issues and delays in fully restoring your CDL status or ability to operate a commercial motor vehicle. 

To ensure you stay in compliance and avoid unnecessary delays, read this guide carefully. We’ll walk you through the Return to Duty (RTD) process, follow-up drug testing requirements, and what you need to know to successfully complete your SAP program.

Understanding the Return to Duty and Follow-Up Testing Process

The First 12 Months: Minimum Testing Requirements

The DOT SAP program mandates a minimum of six follow-up tests within the first 12 months. However, your Substance Abuse Professional (SAP) may require more tests depending on your evaluation. Here's how it works:

- Your SAP determines the total number of follow-up tests over a maximum period of 60 months (5 years).
- Your employer or Consortium/Third-Party Administrator (C/TPA) schedules and conducts the tests.
- If you stop working during this period, your testing schedule pauses and resumes once you return to a DOT-regulated position.

Beware of Common Mistakes

Many drivers mistakenly believe that once their Return to Duty (RTD) test is negative and their Clearinghouse status changes to “Not Prohibited,” they are done. However:

  • The RTD test is only the first step—you still have at least 5 follow-up tests remaining in the first 12-month period.
  • Follow-up tests are separate from random drug tests that your employer may conduct.

From 12 Months to 5 Years: What to Expect

Your SAP will set a follow-up testing schedule, which your employer or C/TPA must follow. This period lasts from a minimum of 12 months to a maximum of 5 years.

- If you stop working for a year, your follow-up testing pauses and resumes upon re-employment.
- You cannot know your test dates in advance—this is a DOT rule to prevent manipulation and assure safety in the industry.
- Your SAP does not select test dates. Instead, they specify how many tests must be completed each year and your employer or the C/TPA plan the actual test dates and inform you each time one is required, until all are completed.

Clearinghouse and Violation Record: What You Should Know

What’s Tracked in the FMCSA Clearinghouse?

The Clearinghouse records:

1. Your first RTD test result.
2. The date you complete all follow-up tests in your SAP plan.

Important: Follow-up tests are not recorded individually in the Clearinghouse, so you must track them with your employer or C/TPA.

How Long Does a Violation Stay in the Clearinghouse?

Even after completing your follow-up testing, your violation remains in the Clearinghouse for 5 years of continuous employment. For example:

- If your SAP ordered 3 years of follow-up testing, your violation will still be visible for 2 additional years of continuous employment.
- This ensures future employers are aware of your violation history, even if your testing is complete.

Completing Step 6: When Are You Fully Cleared?

Step 6 of the Clearinghouse process is not complete until:

  • You complete 5 years of continuous employment under DOT regulations.
  • Your employer or C/TPA properly logs your final follow-up test completion date.
  • If your employer fails to document your completion, it may appear as though you never finished the SAP process.

How to Avoid Issues

  • Check with your employer oor C/TPA regularly to ensure your follow-up testing is on schedule.
  • If your employer goes out of business, ensure your testing records are transferred to a new employer or C/TPA asap.
  • If you suspect errors, contact clearinghouse@dot.gov for guidance.

Final Tips for Staying Compliant

✔ Follow all FMCSA Clearinghouse rules to avoid delays.
✔ Keep communication open with your SAP through step 4, and your employer or C/TPA through all the RTD steps.
✔ Keep documentation of your RTD and follow-up testing.
✔ When changing employers be sure the previous employer shares your testing history with the new employer at the time of new employment.
✔ Understand that RTD and follow-up tests are separate from random and post-accident tests.

Need Help Starting a SAP Program?

Call us now at 1-800-671-8589 or visit ND Assessments to get started!