Who Can Return to Duty Before Finishing Treatment?

If you’re a Substance Abuse Professional (SAP) working across multiple DOT modes like aviation, rail, maritime, or trucking, you’ve probably noticed that not all return-to-duty rules are created equal. One of the most common questions is:

Can an employee return to duty before completing treatment?

Let’s break it down by mode and spotlight the one exception.

What the Regulations Say

Across most DOT agencies, the answer is clear: treatment must be completed before the employee is eligible for a return-to-duty (RTD) test. That includes:

1. Federal Aviation Administration (FAA) -  Requires full completion of treatment before RTD testing.
2. U.S. Coast Guard - Same rule applies and it also triggers a year of non-DOT testing after treatment.
3. Federal Railroad Administration (FRA) -  Again, treatment must be completed before moving forward.

But there’s one outlier.

Federal Motor Carrier Safety Administration (FMCSA): The Exception

FMCSA is the only DOT mode that allows some flexibility. Under FMCSA rules, a SAP may determine that an employee is eligible for RTD testing before completing the full course of treatment, as long as the SAP has conducted a follow-up evaluation and determined the employee is in compliance.

This is a unique allowance, and it’s not mirrored in the other DOT modes.

Why This Matters for SAPs and Employers

If you’re working with FMCSA-regulated employees like commercial truck drivers, you have latitude to make a clinical decision about RTD eligibility before treatment is fully completed. But if you’re working with aviation, rail, or maritime employees, you don’t have that option—treatment must be completed first.

When reviewing the DOT regulations or staff guidelines, keep in mind:

1. FMCSA is the only mode with this flexibility
2. All other modes require full treatment completion before RTD

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