Who Gets the SAP Reports? What Drivers and SAPs Need to Know About C/TPAs and RTD Testing

December 15, 2025

Ophthalmologist's Department

If you are a driver trying to complete a return-to-duty (RTD) test without an employer, or a Substance Abuse Professional (SAP) helping someone through the process, one question comes up often:

Who should receive the SAP reports? Here is a clear explanation.

Why the C/TPA Needs the SAP Reports

When a driver uses the owner-operator workaround to complete an RTD test without an employer, they must:

  1. Register in the Clearinghouse as an independent owner-operator
  2. Designate a C/TPA (Consortium/Third-Party Administrator) to manage the RTD test

In this situation, the C/TPA is acting as the employer for the purpose of the RTD test. Because of that:

  1. The SAP must send the SAP reports to the C/TPA
  2. This includes both the initial assessment and the determination of RTD eligibility

Some C/TPAs may not realize they need these reports, but when they request them, they are following the correct process.

What Should Be Sent

The SAP should send:

  1. The initial SAP evaluation report
  2. The follow-up evaluation report stating the driver is eligible for RTD testing

These documents allow the C/TPA to:

  1. Order the correct RTD test
  2. Report the results to the Clearinghouse
  3. Stay compliant with DOT regulations

What Happens When the Driver Gets a New Job

In an ideal scenario, the new employer would:

  1. Contact the C/TPA that handled the RTD test
  2. Request the SAP reports and the negative RTD test result

This does not always happen. Because of that, SAPs may receive requests to send reports to multiple employers.

Please note: requesting additional reports comes with a $25 administrative fee.

Final Takeaway

If a C/TPA is managing a return-to-duty test for a driver using the owner-operator workaround, they are acting as the employer and should receive the SAP reports.

If a C/TPA requests these documents, the SAP should provide them. It is part of the DOT process and helps ensure the driver can move forward correctly.

Karishma Sarfani

Karishma is a Qualified Substance Abuse Professional (SAP) with a background in mental health and substance abuse counseling, holding credentials as an MS, LCDC, ICADC, CADC II, CSAC, CASAC II, LPC, and EMDR-trained therapist. Inspired by personal experiences with addiction and mental health challenges in her community, she has dedicated her career to supporting individuals on their journey to recovery and success.

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