Frequently Asked Questions
Q: How do I assist my client companies in finding a DOT or NRC qualified SAP or SAE?
A: Provide your client companies with added value service by using SRS as your SAP and SAE referral source.
Q: Does SRS have DOT SAP providers in every state?
A: Yes, SRS has a current network of DOT (SAPs) and NRC SAEs with offices nationwide and in Puerto Rico, the Virgin Islands, Guam and Canada.
Q: Is there any cost for using SRS as a SAP referral source for my clients?
A: SRS offers its services as a complimentary resource for TPAs, MROs and EAPs to share with client companies as added value service.
Q: Does an employer have to terminate an employee who violates a DOT drug or alcohol regulation?
A: No. That is a personnel decision that the employer has the discretion to make, and may be subject to collective bargaining agreements or other legal requirements.
Q: How do I assist my client companies in finding a Non-regulated Substance Abuse Specialist?
A: Provide your Non-regulated client companies with added value service by using SRS as your substance abuse specialist referral source.
Q: Are my client companies responsible for payment of the SAP program?
A: Payment for SAP evaluations and services is left for employers and employees to decide and may be governed by existing management-labor agreements.
Q: Can someone other than the employee direct that an MRO have the employee’s split specimen tested?
A: No. Because the split specimen exists to provide the employee with “due process” in the event that he or she desires to challenge the primary specimen’s results, only the employee can request that the split specimen be tested.
In addition, an employer or a union (or other labor representative) may not act on the behalf of the employee in requesting that the split specimen be tested.
The employee must make the request directly to the MRO.
Q: Can the MRO require an employee’s split specimen test request to be in writing rather than verbal?
A: 40.171(a) states that the employee’s request may be verbal or in writing. Therefore, the MRO must accept a verbal request.
The MRO may ask the employee for written documentation, but must immediately honor the verbal request.
An MRO should always document whether or not an employee requested to have the split tested. The MRO must document the date and time of the employee’s request
Q: If an employee requests his/her records from the MRO, do these records include the MRO’s notes and comments or only copies of the CCF and laboratory result?
A: In general, the MRO should provide all records that are available related to that employee, to include written notes, checklists, or comments. All of this information was obtained from the employee or from appropriate individuals or organizations (with the employee’s authorization) or from documentation provided by the employee.
Consistent with appropriate medical record constraints, the MRO may need to withhold or interpret sensitive medical, psychiatric, and mental health record information.
Q: Can an employer or medical review officer (MRO) enter a drug and alcohol program violation in a CDL driver’s Clearinghouse record if the driver is not registered for the Clearinghouse?
A: Yes. When a violation is entered, the Clearinghouse associates it with a driver’s commercial driver’s license (CDL) information. This will be recorded even if the driver has not registered for the Clearinghouse. When an employer queries a driver’s information in the Clearinghouse (with the appropriate consent), they will enter the driver’s CDL information to verify if any violations are associated with that driver’s CDL.
A driver is required to enter their CDL information during their Clearinghouse registration. This allows them to view any violation or return-to-duty (RTD) information associated with their CDL.
Q: Should a medical review officer (MRO) report a negative-dilute test result in the Clearinghouse?
A: No. The only negative test result reported to the Clearinghouse is a negative return-to-duty (RTD) result, which is reported by the employer or consortium/third-party administrator (C/TPA) in accordance with §§ 382.705(b)(1)(ii) or (b)(6). If the employer receives a negative-dilute RTD result from the MRO, the employer or C/TPA would report it to the Clearinghouse as a negative RTD result.
Q: What are a medical review officer’s (MRO’s) responsibilities for reporting information to the Clearinghouse?
A: Within two business days of making a determination or verification of a Department of Transportation (DOT)-approved drug test, an MRO must report:
- Verified positive, adulterated, or substituted controlled substances test results; or
- Refusal-to-test determination.
The MRO must report any changes of a verified drug test within one business day of making any changes to the reported results.
Registration is required to complete these actions—visit https://clearinghouse.fmcsa.dot.gov/Register to register.
Q: How is driver violation and return-to-duty (RTD) information recorded in the Clearinghouse?
A: Per § 382.705, the following individuals must report the following information:
- Employers, or consortia/third-party administrators (C/TPAs) acting on behalf of an employer, enter drug and alcohol program violation information into the Clearinghouse.
- Medical review officers (MROs) enter drug violation information. The driver does not need to be registered in the Clearinghouse for a violation to be added to their Clearinghouse record.
- Substance abuse professionals (SAPs) enter the date of initial SAP assessment and date the driver is eligible for RTD testing.
- Employers enter the negative RTD test result(s) and the date the driver’s follow-up testing plan has been successfully completed.
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