December 15, 2025

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.
When a driver uses the owner-operator workaround to complete an RTD test without an employer, they must:
In this situation, the C/TPA is acting as the employer for the purpose of the RTD test. Because of that:
Some C/TPAs may not realize they need these reports, but when they request them, they are following the correct process.
The SAP should send:
These documents allow the C/TPA to:
In an ideal scenario, the new employer would:
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.
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.


