Return-to-Duty & Follow-Up Process

Send drivers for Return-to-Duty DOT drug testing after receiving the SAP Evaluation.

• Added to the Random Pool - Drivers are automatically added in the random testing pool and become eligible for random selection after negative Return-to-Duty drug test results are reported by the Express Labs Medical Review Officer (MRO)
• Clearinghouse Reporting - Employers are responsible for reporting negative Return-to-Duty results and the completion of the final Follow-Up test to the FMCSA Clearinghouse.
• Return-to-Duty Results - A negative Return-to-Duty drug test satisfies the DOT pre-employment drug test requirement for new hires

Observed Drug Testing Instructions

Once enrolled, only DOT drug tests ordered through Express Labs are accepted.  If online ordering is unavailable, use the Quest Paper Forms provided by Express Labs.

• Before Testing - Call the collection site to confirm it is open, has a Same-Gender collector and accepting walk-ins.  Most sites will not begin a DOT collection within 3 hours of closing
• Reason for Testing - Return-to-Duty or Follow-Up
• Drug Testing – View Instructions

Clearinghouse Reporting

Employers are responsible for reporting negative Return-to-Duty results and the completion of the final Follow-Up test to the FMCSA Clearinghouse.

• Express Labs does not report Return-to-Duty or Follow-Up result to the Clearinghouse
• Clearinghouse Reporting – View Instructions

Additional Requirements

• Complete Clearinghouse Registration & Queries
• Maintain a DOT Drug & Alcohol Policy
• Complete DOT Supervisor Training
• Additional Requirements – View Instructions

Substance Abuse Professional (SAP)

The SAP evaluation determines when a driver may be sent for Return-to-Duty testing and establishes the Follow-Up testing plan.

• DOT regulations require a minimum of 6 Follow-Up drug tests within the first 12 months, with testing potentially continuing for up to 5 years
• DOT requires driver to Get Tested Immediately when notified for Follow-Up testing
• Employers are responsible for notifying drivers for Follow-Up testing

Owner Operators

Express Labs does not manage the Return-to-Duty or Follow-Up process for owner-operators.

• Owner Operators who have a violation in the Clearinghouse can not enroll in Express Labs Consortium
• Owner Operators who test positive will be removed from the consortium

Express Labs FMCSA Random Drug & Alcohol Consortium
Return-to-Duty | Follow-Up | Updated 2026