When Follow-Up Testing Plans Need to Change: What SAPs and Employers Should Know

In the world of DOT drug and alcohol testing, follow-up testing plans are a critical part of ensuring safety and supporting recovery. But what happens when the plan gets compromised—like when an employer shares the testing schedule with the employee?

Let’s break down what the rules say, what SAPs can do, and why it’s so important to protect the integrity of the process.

Sharing the Testing Schedule Is a Violation

DOT regulations are clear: employers, SAPs, and service agents must not share the follow-up testing schedule with the employee. That includes:

1. The number of tests
2. The duration of the plan
3. The dates or timing of any tests

Why? Because follow-up testing is meant to be unannounced and unpredictable. If the employee knows when they’ll be tested, the purpose of the plan is undermined.

You can find this rule in DOT Rule 49 CFR Part 40 Section 40.307.

What SAPs Can Do If the Plan Is Shared

If a SAP learns that the employer has shared the testing schedule with the employee, they can—and should—revise the follow-up testing plan. This might include:

1. Increasing the number of tests
2. Extending the duration of the plan
3. Adding both drug and alcohol testing, regardless of the original violation

When sending the revised plan, SAPs should include the regulatory citation to reinforce why the change is necessary.

Why SAPs Should Keep Copies of the Plan

Here’s something many people don’t realize: follow-up testing plans are not stored in the DOT Clearinghouse. That means:

1. Employers can’t retrieve the plan through a Clearinghouse query
2. If the employee changes jobs, the new employer may not have access to the plan
3. The SAP may be the only person who still has a copy

That’s why it’s crucial for SAPs to:

1. Keep a copy of every follow-up testing plan they issue
2. Encourage employees to keep all Custody and Control Forms (CCFs) for their records

Final Takeaway

Follow-up testing is a powerful tool—but only if it’s used correctly. If the schedule is shared with the employee, the SAP has the authority to revise the plan and reinforce the rules. And since the plan isn’t stored in the Clearinghouse, SAPs play a key role in preserving the integrity of the process.

So whether you’re a SAP, employer, or driver—stay informed, stay compliant, and keep those records safe.