DOT Follow-Up Testing Plans: Why the Clock Stops When You Are Not Working

If you are a commercial driver who has completed the return-to-duty (RTD) process after a DOT drug or alcohol violation, there is still one important requirement left: the follow-up testing plan. What many drivers do not realize is that the follow-up testing clock only runs while you are working in a safety-sensitive position.

Here is what that means and why it matters.

What Is a Follow-Up Testing Plan

After a driver completes treatment and passes a return-to-duty test, the Substance Abuse Professional (SAP) creates a follow-up testing plan. This plan:

1. Requires at least six unannounced tests during the first 12 months of safety-sensitive work
2. May continue for up to five years
3. Is intended to monitor continued compliance with DOT drug and alcohol regulations

The key point is that the follow-up testing plan only applies while the driver is actively working in a DOT-regulated, safety-sensitive role.

What Happens If the Driver Stops Working

If a driver begins their follow-up testing plan and later stops working in a safety-sensitive position, the plan does not continue running in the background.

The clock stops.

For example, if a driver has a five-year follow-up plan and takes a one-year break from safety-sensitive work, they will still have five years of testing remaining when they return. Time away from work does not count toward completing the plan.

The DOT reinforced this in a November 22 clarification stating that the follow-up testing plan must be administered by the employer when the driver resumes safety-sensitive duties.

Who Administers Follow-Up Testing

Follow-up testing can only be administered by the driver’s employer. This means:

1. A C/TPA may only manage testing if they are acting on behalf of an actual employer or a legitimate owner-operator
2. Unemployed drivers cannot complete follow-up testing on their own
3. Tests taken outside of an employer relationship do not count

Why This Matters

Some drivers mistakenly believe that time off work counts toward completing their follow-up plan. It does not. Others may be offered follow-up testing services while unemployed, but those tests are not valid under DOT rules.

To stay compliant:

1. Do not pay for follow-up testing unless you are employed in a safety-sensitive role
2. Do not assume your plan shortens just because time has passed
3. Resume follow-up testing only when you are back to work

Final Takeaway

A DOT follow-up testing plan is based on time spent working in a safety-sensitive position, not calendar time. Whether your plan lasts 12 months or five years, it only progresses while you are actively employed in a DOT-regulated role.

If you are unsure about your status, confirm details with your SAP or employer to avoid delays or compliance issues.