Table of Contents
After you’ve violated the DOT’s drug and alcohol rules and have completed your SAP evaluation and treatment recommendations, you must complete follow-up testing after you return to work.
As a DOT-qualified SAP, American River Wellness creates follow-up testing programs for CDL drivers and other safety-sensitive workers who have completed our SAP process and are returning to work.
This guide explains what to expect during your follow-up testing program and how to stay compliant so you can keep driving.
Key Takeaways
- Follow-up testing is a mandatory series of regular, unannounced drug tests you must take after you complete the RTD process and return to work.
- You must take follow-up drug tests to comply with federal regulations, protect public safety, maintain sobriety, aid in your recovery process, and rebuild your professional reputation.
- Once you’ve completed your SAP’s treatment recommendations, they will write a follow-up testing plan based on your violation and substance use history that will last from one to five years.
What is DOT Follow-Up Drug Testing?
DOT follow-up drug testing is a mandatory series of unannounced 5-panel drug tests that individuals must take after completing the return-to-duty (RTD) process and returning to work.
Why Do You Have to Take a Follow-Up Drug Test?
1. Mandated by Federal Regulations
Under 49 CFR Part 40, Subpart O § 40.291(a)(5), 49 CFR Part 40 Section 40.23, and FMCSA rule 6.5.6, follow-up testing is required after a drug and alcohol violation to stay compliant with DOT regulations.
It’s a mandatory part of the return-to-duty process, and employers must enforce it as written by the SAP.
Whether you return to work with your employer or start a new job with a DOT-regulated employer, you must complete follow-up testing as recommended by your SAP.
If you skip, refuse, or fail any follow-up test, you’ll be removed from safety-sensitive duties and must restart the entire return-to-duty process.
2. Protects Public and Workplace Safety
The work performed by CDL drivers and other DOT-regulated workers is safety-sensitive.
If a safety-sensitive worker is impaired by drugs or alcohol while on the job, other workers and members of the public could face significant risks of harm.
Follow-up testing helps protect public and workplace safety by making sure you remain unimpaired on the job after returning to work.
3. Confirms Ongoing Sobriety and Supports Recovery
Follow-up tests help you remain sober after you return to duty.
Since you know that you’ll have to undergo regular, unannounced drug and alcohol tests, you’ll be less likely to use these substances.
The structured program provides accountability to you and helps you stay on track.
This helps you remain sober so that you can keep your job.
4. Rebuilds Professional Credibility
After you violate the DOT’s drug and alcohol rules, it damages your professional reputation.
Successfully completing follow-up testing demonstrates your reliability and commitment to compliance and helps rebuild your professional reputation.
What to Know About DOT Follow-Up Testing Process
Your SAP Creates a Personalized Testing Plan
Once you complete your SAP’s treatment recommendations and pass a return-to-duty drug test under direct observation, your DOT-qualified SAP will create a written follow-up testing plan
Your plan will outline the following:
- How many tests you’ll take
- How often testing will occur
- How long your follow-up testing program will last
Your SAP’s plan is based on your history, progress, and the nature of your violation.
It becomes part of your official Return-to-Duty agreement with your employer.
Testing Methods Used in Follow-Up Programs
Follow-up drug tests use the same DOT-approved testing methods as your initial drug test and must be done under direct observation.
Urine testing remains the standard under DOT regulations. Your tests will be directly observed under federal regulations.
Each test follows strict chain-of-custody and observation procedures to ensure accurate, tamper-proof results.
Your sample will be sealed in your presence and reviewed by a Medical Review Officer (MRO) before being reported to your employer and entered in the FMCSA Drug & Alcohol Clearinghouse.
Tests Are Completely Unannounced
You won’t know when your next test is coming.
Follow-up tests are random and unannounced, ensuring fairness and accountability.
You’ll only be notified when it’s time to report to the collection site.
Once notified, you must report to the testing site immediately or as soon as you can safely wind down safety-sensitive duties you’re engaged in, if applicable.
You must report within the provided time frame and remain at the testing site until your test is completed.
If you fail to report on time or leave the center early, it will be counted as a failed test.
The Program Typically Lasts 1 to 5 Years
DOT regulations require a minimum of six unannounced tests within the first 12 months.
Depending on your violation and your SAP’s recommendations, testing can continue for up to 60 months (five years).
For example, if your violation involved repeated substance use or occurred while performing safety-sensitive duties, your SAP may require a longer or more frequent testing schedule to confirm ongoing recovery.
Your Employer Handles the Logistics
Your employer is responsible for all of the following:
- Scheduling your tests based on SAP’s plan
- Coordinating with collection sites or third-party administrators
- Reporting results to the FMCSA Drug & Alcohol Clearinghouse
You must comply with every scheduled test and submit negative results to stay eligible for driving or other safety-sensitive work.
If you fail or refuse a follow-up test, you’ll have to restart the RTD process.
Driver Responsibilities During the Follow-Up Program
To stay compliant throughout your program, you’ll need to:
- Stay in communication with your SAP and employer.
- Be available for unannounced testing at all times.
- Report to the testing site immediately when notified.
- Submit negative results.
- Notify new employers of your ongoing testing plan if you change jobs.
- Continue meeting all FMCSA and DOT compliance requirements.
Costs and Who Pays
Drivers are typically responsible for paying for their SAP evaluation and treatment program.
Employers typically pay for follow-up drug tests, though some may require reimbursement.
Costs vary based on your treatment plan and the number of required tests.
Staying compliant helps you avoid repeat violations, which can be far more expensive in the long run.
Completing the Follow-Up Testing Program
You’ll complete your program once you’ve successfully finished all tests required by your SAP.
Your employer will document completion of the follow-up plan, not the SAP, and your record will be updated in the DOT Clearinghouse.
Completing the program demonstrates your long-term commitment to safety, compliance, and professional responsibility.
Failing or Missing a Test Has Serious Consequences
If you refuse, skip, or fail a follow-up test, you’ll face the following consequences:
- Immediate removal from safety-sensitive duties
- Automatic suspension of your CDL (if a CDL driver)
- Forced restart of the SAP process, including another evaluation and treatment plan
- Potential loss of a job
Passing every test on schedule shows your employer and the DOT that you’re serious about recovery and maintaining safety as a safety-sensitive worker.
How to Stay on Track During Your Follow-Up Testing
To stay on track during your follow-up testing program, take the following steps:
- Respond quickly to all test notifications by reporting to the testing site immediately. If you’re performing safety-sensitive work when notified, wind it down as safely and quickly as possible and then report.
- Keep your phone on and schedule flexible to stay available for unannounced tests.
- Bring your valid photo ID and paperwork to every collection site.
- Organize your SAP reports, test results, and receipts in one place.
- Maintain a support network that encourages sobriety and accountability.
- Avoid using illicit substances at all times.
- Don’t use alcohol while on duty or within multiple hours before and after duty.
- Know your rights and responsibilities under 49 CFR Part 40.
- Follow your SAP’s treatment or aftercare plan and treat each test as progress toward full reinstatement.
Get Help from American River Wellness
If you’re a safety-sensitive worker who has violated the DOT’s drug and alcohol rules, you’ll have to complete the return-to-duty process to return to work.
Whether you return to working for your employer or go to work for a new DOT-regulated company, you must complete follow-up testing as recommended by your DOT-qualified SAP.
To return to work fast, get started now by contacting the DOT-qualified SAPs at American River Wellness today at (833) 436-8727.
DISCLAIMER: This information is intended solely for educational and informational purposes. It should not be interpreted as legal counsel or guidance.
FAQ
Drug and alcohol violations, your completion of the RTD process and RTD drug test, and follow-up drug and alcohol tests will be reported to the FMCSA Drug & Alcohol Clearinghouse.
Prospective employers will see this information until you’ve completed your requirements.
Different DOT administrations have specific testing requirements for the safety-sensitive workers they regulate.
For example, according to the Department of Transportation, the FMCSA has a 50% random drug testing rate, while the FAA requires a 25% random drug testing rate.
However, all DOT administrations follow the general DOT drug and alcohol rules as outlined in 49 CFR Part 40, including the requirement for follow-up testing once a safety-sensitive worker returns to their job after completing the RTD process.
Yes, you can drive for a different company during follow-up testing.
However, your new employer must also comply with your SAP’s recommendations for follow-up testing and will see that it’s required for you based on information reported to the FMCSA Drug & Alcohol Clearinghouse.
About the Author
