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Follow-Up Testing (RTD Step 6) is the final phase of the DOT Return-to-Duty process and begins after a driver successfully completes the RTD Step 5 drug test.
This testing program is mandatory, unannounced, and directed by a DOT-qualified Substance Abuse Professional (SAP). Its purpose is to monitor continued compliance and ensure long-term safety for DOT safety-sensitive positions.
Follow-Up Testing is required for all CDL drivers who had a DOT drug or alcohol violation, completed SAP evaluation and education or treatment, passed the RTD Step 5 test, and are returning to safety-sensitive duties.
This applies to company drivers, owner-operators, and independent contractors.
*Include Follow-Up Plan Setup For $100.00*
*FMCSA Clearinghouse Reporting $30.00*
*Include Observed Urine Drug Test For $99.95*
*FMCSA Clearinghouse Reporting $30.00*
| Testing Type | Purpose |
|---|---|
| Follow-Up Testing (Step 6) | SAP-mandated monitoring after a violation |
| Random Testing | Ongoing DOT compliance for all drivers |
Follow-Up Testing is in addition to random testing — not a replacement.
The SAP establishes the number of required follow-up tests, the duration of the program (up to 5 years), and whether drug, alcohol, or combined testing is required.
Minimum requirement: At least 6 unannounced tests in the first 12 months
Drivers are not notified in advance. Tests may occur at any time during the follow-up period, and employers or C/TPAs receive testing instructions without prior notice to the driver.
Depending on SAP instructions, tests may require direct observation. The same DOT collection standards apply, and testing occurs at DOT-certified collection sites.
Specimens are processed at HHS-certified labs. Results are reviewed by a licensed Medical Review Officer (MRO), and verified results are finalized before reporting.
Follow-Up Testing compliance is recorded in the FMCSA Clearinghouse. Employers and authorized parties can verify driver status, and missed or failed tests are reported as violations.
Follow-Up Testing lasts a minimum of 12 months and may continue for up to 5 years. The duration is determined solely by the SAP and cannot be shortened by employers or drivers.
The SAP may reduce or end testing early only if continued compliance is demonstrated.
A missed or failed follow-up test results in an immediate DOT violation. The driver becomes prohibited again, a new SAP evaluation is required, and the RTD process must restart from the beginning.
goMDnow assists drivers and employers by managing follow-up testing schedules, coordinating nationwide DOT collection sites, ensuring SAP instructions are followed correctly, supporting employer and owner-operator compliance, and maintaining accurate records and reporting.
20,000+ DOT collection locations nationwide
Employers must ensure tests are completed as scheduled, maintain confidentiality, act immediately on missed or positive tests, and comply with Clearinghouse reporting requirements. Failure to comply may result in FMCSA penalties.
No. Step 5 is a one-time return-to-duty test required after a violation. Random testing resumes only after Step 6 begins.
Yes. Owner-operators may complete RTD Step 5 using a qualified C/TPA, provided Clearinghouse requirements are followed correctly.
The driver remains prohibited and must:
No. Follow-Up Testing is SAP-directed, not random, though it is unannounced.
At least 6 tests in the first 12 months, with additional testing possible for up to 5 years.
No. Refusal is considered a DOT violation and immediately disqualifies the driver.
Yes. Owner-operators must comply with SAP-directed follow-up testing just like company drivers.
Yes, depending on the original violation and SAP instructions.
Yes. Compliance and violations are recorded and visible to authorized users.
| Step | Description |
|---|---|
| Step 5 | One-time Return-to-Duty drug test |
| Step 6 | Ongoing SAP-directed follow-up testing |
Drivers must complete Step 5 first before entering Step 6.
Whether you are an employer, an owner-operator, or a driver returning to duty, goMDnow can help manage your DOT Follow-Up Testing program correctly.
