DOT Medical Exams and SAP Referrals: What You Need to Know About Questions 31 and 32

If you're a CDL driver or work in a safety-sensitive role, you’re required to pass a DOT Medical Examination every 24 months or more often, depending on your health. This exam ensures you’re physically and medically fit for duty.

But one part of the exam tends to trip people up: the driver health history form, especially questions 31 and 32. Let’s break down what these questions ask, why they matter, and what they mean for you as a driver or for a SAP who might get involved.

The Tricky Questions on the DOT Health History Form

On the medical history form, you’ll be asked:

31. Have you used an illegal substance within the past 2 years?
32. Have you ever failed a drug test or been dependent on an illegal substance?

They’re considered red flags by DOT-certified medical examiners (MEs). Answering “yes” to either one can trigger a referral to a substance use expert, and that’s where confusion often begins.

What Happens Next? Is This a SAP Assessment?

Not exactly. Here’s the clarification: This is not an official DOT SAP evaluation as defined under Part 40 or Part 382. The referral is for an expert opinion, but it’s not subject to the DOT return-to-duty process.

Why? Because the drug or alcohol test ordered by a medical examiner during your medical exam is considered a non-DOT test under Part 40. Even though it’s part of the DOT medical certification process, it’s not a DOT drug test in the regulatory sense.

DOT confirmed this in a 2024 guidance update: “A drug or alcohol test performed during a DOT medical examination is not a DOT test under Part 40, and does not require a SAP evaluation.”

Then Why Do Medical Examiners Refer Drivers to SAPs?

DOT-qualified medical examiners are allowed under Part 40 to request expert evaluations when needed—especially if there’s a history of substance use.

They may tell you to “go see a SAP,” but what they’re really asking for is:

1. A professional with DOT-level knowledge of drug and alcohol concerns
2. An informed opinion on your ability to operate a commercial vehicle safely
3. Clinical guidance—not a regulatory process

Important note for SAPs: Even if you’re the one receiving this referral, you are not conducting an official DOT SAP evaluation. That means:

1. You’ll need a signed release of information
2. You should use your own reporting format
3. You are not operating under Part 40 and do not report to the Clearinghouse

Final Thoughts

If you’re a driver filling out the DOT medical form, answer honestly. But keep in mind that certain responses may lead to a referral, even if you’re fully compliant with DOT drug and alcohol testing rules. If you’re a SAP receiving one of these referrals, it’s important to understand that this is not a DOT SAP case. You’re acting as a clinical consultant rather than a regulator, and while the process falls outside the DOT SAP framework, confidentiality and appropriate documentation still apply.