Face-to-Face Evaluations in DOT Testing: What You Need to Know

If you are part of a DOT-regulated, safety-sensitive workforce and receive a positive drug or alcohol test, you will be required to complete an evaluation with a Substance Abuse Professional (SAP). One important rule applies to every case:

All SAP evaluations must be conducted face-to-face. Let’s break down what that means and what it does not.

Face-to-Face Does Not Always Mean In Person

Under current DOT Part 40 guidance, face-to-face evaluations may be conducted remotely, as long as one key requirement is met:

The SAP must be able to see and hear the employee during the evaluation.

This means video-based evaluations using platforms such as Zoom or Microsoft Teams are allowed. Audio-only phone calls, emails, or text-based communications do not meet DOT requirements.

Why This Rule Changed

Remote SAP evaluations became more common during the COVID-19 pandemic, when in-person meetings were not always possible. After reviewing outcomes, the DOT determined that remote evaluations could be clinically appropriate when conducted properly.

As a result, remote face-to-face evaluations are now a permanent and acceptable option under DOT regulations.

How SAPs Decide Between In-Person and Remote Evaluations

There is no single rule that applies to every case. SAPs use professional judgment when deciding how evaluations are conducted. Approaches vary by provider and situation.

Some SAPs primarily conduct remote evaluations. Others require in-person sessions. Many use a hybrid approach depending on clinical needs.

For example:

1. An initial evaluation may be conducted in person to establish a thorough clinical assessment
2. Follow-up evaluations may be completed remotely if the case is straightforward
3. More complex cases may require all evaluations to remain in person

The format is chosen based on what best supports an accurate and ethical evaluation.

What This Means for Employees

If you are going through the SAP process, you should be prepared to participate fully, whether the evaluation is conducted in person or remotely.

For remote evaluations:

1. Ensure you have a reliable internet connection
2. Use a device with working video and audio
3. Be in a private, distraction-free environment

Understand that the SAP determines the evaluation format based on clinical judgment, not convenience.

Final Thought

Whether conducted in a clinic or through a secure video platform, the purpose of a face-to-face SAP evaluation is the same: to ensure the assessment is thorough, compliant, and tailored to the individual.

Face-to-face does not mean inflexible. It means direct, real-time interaction that supports accountability, accuracy, and public safety.