C/TPAs and Follow-Up Testing: Who Does What in the DOT Process?

If you’re an employer, SAP, or safety-sensitive employee navigating the DOT return-to-duty process, you’ve probably heard of Consortium/Third-Party Administrators (C/TPAs). These service agents can be incredibly helpful—but it’s important to understand what they can and can’t do, especially when it comes to follow-up testing.

Let’s clear up the confusion.

What Can a C/TPA Do?

A C/TPA can be hired by an employer to help manage the logistics of a DOT drug and alcohol testing program. For follow-up testing, they can:

1. Notify employees when it’s time to test
2. Schedule and coordinate collection appointments
3. Send employees to collection sites
4. Transmit results to the employer

They’re essentially the administrative arm of the employer’s testing program.

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What Can’t a C/TPA Do?

Here’s where it gets critical: C/TPAs cannot set the dates for follow-up tests. That responsibility belongs to the Designated Employer Representative (DER).

Why? Because follow-up testing is based on an individualized plan created by the SAP. It’s not like random testing—you can’t just throw everyone into a pool and pull names.

The employer must:

1. Follow the SAP’s plan
2. Decide when to conduct each test
3. Ensure the tests are unannounced and unpredictable

Who Gets the SAP Reports?

If a C/TPA reaches out asking for the SAP’s follow-up testing plan, remember this:

1. The SAP’s reports go to the employer’s DER, not the C/TPA
2. The employer can then share the plan with the C/TPA if they choose

This ensures the employer remains in control of the testing process and timing.

What If the Plan Needs to Change?

Sometimes, new information comes to light—like a driver testing positive in a treatment program. In that case:

1. The SAP can issue a revised follow-up testing plan
2. This is the only tool the SAP has after declaring the driver eligible for return-to-duty testing

If the driver has a second violation, the original plan is void. The new SAP creates a new plan, and the employer follows that one instead.

Final Takeaway

C/TPAs are valuable partners—but they’re not in charge. Employers must:

1. Set the dates for follow-up tests
2. Follow the SAP’s individualized plan
3. Keep control of the process, even if they outsource the paperwork

And SAPs? Your reports go to the DER. Always.

Because when it comes to DOT compliance, clarity and control are everything.