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.

Comply with 2020 mandatory Clearinghouse Rule (part 1)


On January 6, 2020, the Clearinghouse Rule, implemented by Congress in 2016, goes into mandatory effect.

How does this impact drivers and companies?

It depends on the size of your fleet, but one fact is clear, every carrier must participate.

Of course, all drivers with a CDL have already had to comply with the FMCSA Drug and Alcohol regulations. Until now, all CDL drivers should have been in a random drug-and-alcohol consortium. However, the new Rule goes a step further than that.

Beginning January 6, 2020, all drivers holding a CDL are responsible for setting up an account in the Clearinghouse, including large-to-mid-sized fleets and owner-operators.

If you need assistance setting up an account in the Clearinghouse, please call us at 888.260.9448 or email us at info@cnsprotects.com.

The FMCSA is aware that not all CDL drivers are currently registered in a drug-and-alcohol consortium. With the new regulations finally going into effect, it will be virtually impossible for owner-operators to avoid being in the Clearinghouse.

For instance, all drivers need to have an annual query (an electronic check) run in the Clearinghouse. Therefore, an owner-operator, employing themselves as a single-driver, must hire a consortium or third-party administrator (C/TPA) to run a query.

Or, a driver looking to switch employers needs to be in the Clearinghouse for a prospective employer to run a full query. Queries will show whether there is anything in the Clearinghouse on that driver that requires further investigation or prohibits them from performing safety-sensitive functions.

We offer a comprehensive Drug and Alcohol Consortium Services and are a certified consortium and third-party administrator (C/TPA). If you are in need consortium management, contact us at 888.260.9448 or info@cnsprotects.com.

What information is stored in the Clearinghouse?

The CDL Drug and Alcohol Clearinghouse will store three years of data on drivers including positive drug tests, test refusals, and alcohol violations. Complete and incomplete return-to-duty processes will also be recorded. This information will remain in the Clearinghouse database for three years.

Employers and fleets may run two types of queries:

  • Full queries (required for new hires) supply all information details
  • Limited queries (required for all drivers annually) will only reveal whether or not the database contains any information on the driver; carriers can ask for full queries after that finding

Ensure compliance with new FMCSA Drug and Alcohol Regulations

Now that the Clearinghouse Rule becomes mandatory in less than a month, here’s what drivers and companies can do to become compliant:

CDL Drivers

All CDL drivers need to have an account for any prospective or current employer to run the required new-hire queries. Drivers can also view records and petition for any corrections as needed.

If you are a CDL driver, you can follow the steps below.

  1. Register an account in the Clearinghouse
  2. Provide electronic consent to release information during a full query
    1. If a driver does not give consent within 24 hours, they are disqualified from driving until authorization is given
  3. Review records for accuracy
  4. Identify a Substance Abuse Professional (SAP) to report on return-to-duty activities if unresolved violations are on record

Owner-operators (one-truck/independent)

Any single-driver operation must comply with requirements for BOTH employees (drivers) and employers (fleets/companies).

If you are a one-truck or independent owner-operator, you can follow the steps below.

  1. Register an account in the Clearinghouse as a company
  2. Designate a consortium or third-party administrator (C/TPA) to handle queries. This is required of all owner-operators (Contact Compliance Navigation Specialists)
  3. Notify the consortium (or TPA) that they are the designee.
  4. Amend any contracts to reflect the designated consortium (Designation and contract amendments will be two separate steps, and both must be carried out)
  5. Purchase bundles of queries for the consortium to query the database on an annual basis

OPTIONAL: Invite assistants/other employees to allow them access to the Clearinghouse on your behalf. They should register as part of your company.

Owner-operators (leased)

If you are a leased owner-operator, you can follow the steps below.

  1. Register an account in the Clearinghouse
  2. Although not explicitly stated in the Rule, an account is needed for switching fleets, as each new fleet will need to make a query
  3. Provide electronic consent for full queries

Small and large fleet operators

The two main changes for small and large fleet operators are amending policies and employee information.

If you are a small or large fleet operator, you can follow the steps below.

  1. Register as an employer in the Clearinghouse
  2. Purchase bundles of queries
  3. Amend fleet policies to reflect that any positive drug tests, test refusals, or violations will be submitted to the Clearinghouse
  4. Explain these new policies to drivers prior to January 6, 2020
  5. Determine if administration of drug-screening will be handled in-house or outsourced. If outsourced, designate the provider in the Clearinghouse and contract them as a designee (Designation and contract amendments will be two separate steps, and both must be carried out)
  6. Continue to call applicant’s prior employees to ask about failed or refused drug tests until 2023. Since the Clearinghouse will not reflect past data, it will take three years until the Clearinghouse is fully up-to-date.

OPTIONAL: Designate a consortium or third-party administrator (C/TPA) to handle queries.

Learn more about changes to Clearinghouse reporting forms


Drug and Alcohol Services

Register now to ensure compliance with FMCSA regulations

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.

DOT drug test: Who, what, when and how


As directed by the Federal Motor Carrier Safety Administration (FMCSA) and the Department of Transportation (DOT), all CDL drivers and their employers are required to follow the rules related to DOT drug tests.

Who is given a DOT drug test?

Drivers of commercial motor vehicles (CMVs) are required to take a drug test and their employers must ensure their drivers are tested before operating a CMV.

Below is a full list of those required to be tested.

  • employers of CDL drivers operating CMVs on public roads
  • CDL drivers who operate CMVs on public roads
  • interstate motor carriers
  • intrastate motor carriers
  • federal, state, and local governments
  • civic organizations (disabled veteran transport, boy/girl scouts, etc.)
  • faith-based organizations

What substances are tested?

The DOT requires testing of alcohol and five drug classes, including:

  1. Marijuana
  2. Cocaine
  3. Opiates
  4. Amphetamines or methamphetamines
  5. PCP

Alcohol tests will identify alcohol in the system at .02 BAC and more.                      

Motor carriers can also implement a separate testing program in addition to, and distinct from, the required DOT testing program, under which they are able to test for other drugs.

What types of DOT drug tests are there and when are they given?

DOT drug and alcohol tests are given in several different scenarios, including:

  1. pre-employment – before starting work as a CDL driver and operating a CMV
  2. post-accident – drug and alcohol tests may be required after an accident depending on the circumstances. Learn when post-accident drug tests are required.
  3. random – random testing programs are required by law for all DOT-regulated motor carriers
  4. reasonable suspicion – if a driver appears to be under the influence of drugs or alcohol, an area in which supervisors must be trained in identifying.
  5. return-to-duty – required of drivers who tested positive, refused, or violated the law
  6. follow-up – required of drivers who tested positive, refused, or violated the law

What is the DOT drug testing process?

The DOT has a strict process for administering drug tests and the steps are the same for all six types.

  1. Go to the collection site with a valid ID and provide a sample before leaving.
  2. Provide your urine sample in the designated collection area. The collection process will be private unless required, as in a return-to-duty or follow-up test.
  3. When finished with the sample, provide the container to the collector and observe as they split the sample into two containers, seal them with tamper-evident tape and allow you to sign the tape before you leave.
  4. Provide your contact information and verify your name and date of birth so the Medical Review Officer (MRO) can get in touch with the results.

Drug and alcohol testing

Where does a driver get a DOT drug test?

Compliance Navigation Specialists works with Quest Diagnostics and have over 10,000 locations available for testing, whether it is necessary after an accident or for a pre-employment screening.

We also offer a comprehensive Drug and Alcohol Consortium Administration Services (C/TPA) for companies that are regulated by Federal and State government.

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

DOT post-accident drug test requirements


As a DOT-regulated motor carrier, it is extremely important to ensure all CDL drivers are in top physical and mental condition while operating these highly complex and powerful commercial motor vehicles. Driver awareness of post-accident drug test requirements is also crucial.

Although we do everything possible to prevent accidents, there are times when circumstances are beyond our control, making the post-accident steps one of the most important pieces of knowledge for a CDL driver. A driver’s responsibilities do not stop at the site of the accident.

What are the different types of DOT drug tests?

There are several situations in which a DOT drug test is required, including:

  1. pre-employment – before starting work as a CDL driver
  2. post-accident – applies to certain situations following an accident
  3. random – random testing program require by law for all DOT-regulated motor carriers
  4. reasonable suspicion – if a driver appears to be under the influence of drugs or alcohol
  5. return-to-duty – required of drivers who tested positive, refused, or violated the law
  6. follow-up – required of drivers who tested positive, refused, or violated the law

When is a post-accident drug and alcohol test required?

Drug and alcohol tests are not required after every accident. A CDL driver is required to take a post-accident drug test if:

  • the accident results in one or more fatalities
  • injury was incurred that required medical treatment away from the scene and the driver received a citation (Note: no citation = no drug and alcohol test)
  • any vehicle is towed, and the driver received a citation (Note: no citation = no drug and alcohol test)

Also, it is important to note that a driver is still liable to take a drug and alcohol test if a citation issued within 32 hours of the accident. If a citation is issued after the 8 hour mark, the motor carrier must make a note saying “a citation was not issued until this time, which was after the 8 hours for alcohol testing.”

How much time do I have to get a post-accident drug test?

A driver has 2 hours in which an alcohol test should be completed, however it must be completed within 8 hours. If the driver goes over the 2-hour mark, they must provide an explanation as to why there was a delay and the motor carrier must provide a written explanation and keep in their company files.

A drug test needs to be completed as soon as possible; however, it must be completed within 32 hours. At times there might be a delay in the issuance of a citation, however as long as the citation is issued with 32 hours, a drug and alcohol test is required.

Drivers often run into issues with meeting these timeframes because they will be kept at the scene of an accident for several hours or an investigation must be completed to determine if the driver was at fault.

What if I miss the maximum time frame allowed?

If a driver does not get his post-accident drug test before the maximum allowed time, the company needs to make a note in their files as to the reason why, however it is too late and the company will be out of compliance and face fines and audit penalties, so completing the drug test within the allowed time is imperative.

What about on-site tests, such as a DUI test or breathalyzer?

If an officer conducts a DUI test or a breathalyzer at the scene of an accident, a driver is still required to follow protocol and get an official drug and alcohol test within the allotted time frames. An on-site test by an officer will not fulfill the required DOT post-accident drug test as these tests do not follow DOT rules and regulations.


Drug and alcohol testing

Where does a driver get a DOT drug test?

Compliance Navigation Specialists works with Quest Diagnostics and have over 10,000 locations available for testing, whether it is necessary after an accident or for a pre-employment screening.

For post-accident alcohol testing, CNS will coordinate a location for you.

We also offer a comprehensive Drug and Alcohol Consortium Administration Services (C/TPA) for companies that are regulated by Federal and State government.

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