2020 Clearinghouse Rule changes: Forms Reporting (part 2)


The new 2020 Clearinghouse Rule went into effect on January 6, 2020. Even as new laws are rolled out, there can be last minute changes. At CNS, we want to be sure we’re keeping you up to date on the latest news and information regarding the Clearinghouse, as well as other U.S. DOT regulations.

On December 17, 2019, the U.S. Department of Transportation released a bulletin changing the data requirements on two of their forms relating to the Clearinghouse.

Here’s what is important to know about the upcoming change in recording information on these forms.

Which forms are being changed?

The two forms being changed are:

What has changed on the forms?

The main change to these forms is the way drivers are identified in the form when positive test results are reported.

Currently, you can use either the driver’s social security number (SSN) or their employee Identification number (EIN) when recording on these forms.

Effective January 6, 2020, you will be required to use the commercial driver’s license number (CDL) only when positive drug or alcohol tests are reported via these two forms.

Who do these form changes affect?

  • Employers
  • Consortia/Third Party Administrators (C/TPAs)
  • Collection sites
  • Laboratories
  • Medical Review Officers (MROs)

How can I stay compliant with this change?

Our Compliance Specialists can assist you with any questions you might have. Please call us at 888.260.9448 or email us at info@cnsprotects.com.

Employers should check data systems to ensure compliance

The best way to ensure compliance when reporting positive drug and alcohol test results to the Clearinghouse via the CCF and ATF forms is to check your current data systems. Moving forward, data systems need the capability to input an identification number of up to 25 characters in order to enter a CDL number.

Employers must annotate accurately

When completing the CCF or the ATF, the entry personnel “must annotate the driver’s CDL number and State of Issuance in Step 1, Section C of the CCF or Step 1B of the ATF for each FMCSA-regulated test.”

Medical Review Officers (MROs) should follow up on missing data

When an MRO receives a CCF form without a driver’s CDL number and State of Issuance, they should follow up to obtain this missing data. Contact the driver, the driver’s employee, or the designated employer representative to obtain the accurate information.

The MRO should report all verified positive tests results in the Clearinghouse.

Stay updated on the new Clearinghouse Rule

As the new Clearinghouse rolls out in 2020 and into the future, there may be more changes and adjustments. The CNS blog will keep you updated on all news, changes, and support you and your company in staying compliant with the new Clearinghouse Rule.

Please be sure your company and your employees register with the Clearinghouse by January 6, 2020 to avoid delays in processing forms and new hires.

For additional information on the Clearinghouse, including FAQ and Registration information, visit https://clearinghouse.fmcsa.dot.gov.


Drug and Alcohol Services

Compliance Navigation Specialists offer a comprehensive Drug and Alcohol Consortium Administration Services (C/TPA).

We work with Quest Diagnostics and have over 10,000 locations available for testing.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.