Follow-Up Testing Plans: What SAPs Can—and Can’t—Do

If you’re a Substance Abuse Professional (SAP), employer, or DOT-regulated employee, you’ve probably heard about follow-up testing after a return-to-duty (RTD) process. But what exactly goes into a follow-up testing plan—and who decides what?

Let’s clear up the confusion.

What Is a Follow-Up Testing Plan?

According to the DOT, a follow-up testing plan includes the SAP’s recommendation for:

1. The number of tests
2. The duration of the testing period
3. The type of tests (drug, alcohol, or both)

This plan is handed off to the employer, who is responsible for carrying it out.

Drug or Alcohol—or Both?

Even if the employee only tested positive for one substance, the SAP can recommend testing for both drugs and alcohol. Why?

Because:

1. Substance use patterns can shift
2. Testing both helps monitor for relapse or substitution

Many SAPs recommend always including both, regardless of the original violation. But ultimately, it’s up to the SAP’s clinical judgment.

Can SAPs Pick the Test Dates?

No. That’s the employer’s job. SAPs cannot set specific dates for follow-up tests. However, they can suggest that some tests be scheduled around triggering events, such as:

1. Holidays (New Year’s Eve, July 4th)
2. Birthdays
3. Long vacations

These are times when relapse risk may be higher, so it’s smart to flag them—but the final call is the employer’s.

What About the Testing Method?

Follow-up tests must be directly observed. That means:

1. Oral fluid (saliva) testing qualifies as observed
2. Urine testing is still the gold standard for detecting patterns of use

SAPs can recommend a testing method, but employers aren’t required to follow that advice. Some may prefer oral fluid testing for convenience, while others stick with urine for its broader detection window.

Final Takeaway

As a SAP, your role is to define the type, frequency, and duration of follow-up testing. You can suggest timing and technology, but you don’t control the calendar or the method.

Employers, on the other hand, are responsible for:

1. Scheduling the tests
2. Choosing the testing method
3. Ensuring the plan is followed

Together, this partnership helps support recovery, ensure compliance, and keep transportation industries safe.