NEW Information (edited by Dr. Kurt Meininger, DC, CME, C/TPA - 06/22/25):
STEP 6:
STEP 6 is the Follow-up Testing Plan… which is created specifically for YOUR CASE by YOUR SAP.
You CANNOT start STEP 6… according to the FMCSA… until you start driving a CDL truck with a “DOT Regulated” company… driving under their authority!
*The only exception to this rule is if you are an "Owner Operator" driving under your own authority… then you can start STEP 6 immediately!
But, If you are currently unemployed… looking for a CDL job… or if you are doing a different type of job (like Uber or driving a Box Truck)… then you CANNOT start STEP 6.
It is perfectly fine to POSTPONE your follow up testing plan. It doesn’t matter if it takes you 3 months or 6 months or up to 2 years to find a CDL job… you can POSTPONE your STEP 6.
After you get your new CDL job… YOUR EMPLOYER will need to contact your SAP… who will email your follow-up testing plan… NOT to YOU… but directly TO YOUR EMPLOYER!
The SAP’s follow-up testing plan is confidential and you are NOT allowed to ask or know.
The SAP’s follow-up testing plan consists of a minimum of 6 observed drug tests… sometimes more. Sometimes breath alcohol is also included…
Every SAP is different and every follow-up testing plan is specific and unique according to YOUR case.
These drug tests are spread out over a whole year or more... and are managed similar to the normal random drug and alcohol program…
Your employer has the authority and will manage your Follow-Up testing plan. They will eventually upload your very last follow-up test… and complete STEP 6… inside your Clearing house.
But, If your employer has NO experience with the Clearing House… or has some Confusion and Uncertainty… about the whole SAP process… or has several Questions about STEP 6… and NEEDS HELP managing your follow up testing plan… they are welcome to contact me!
I will walk them through the entire RTD process and STEP 6... explain all the details and compliance rules... and if they want my expertise... they are welcome to Authorize and Designate me as their C/TPA!
I can be reached at 678-925-1878.. or email... drkurtmeininger@gmail.com
Your SAP is only authorized, according to the FMCSA rules, to send your "confidential" Follow-Up Testing Plan to your employer... but your employer can designate me… as their Consortium - Third Party Administrator (C/TPA)… to help schedule and manage your follow-up testing plan.
There is a high likelihood that your employer has already designated a C/TPA... who is well versed in the RTD process... and will know exactly how to mange your STEP 6 Follow-Up Testing Plan.
Your employer can require you to take several drug tests within the same month… they can mix it up anyway they want... and we encourage that!
Remember these "observed" drug tests are NOT planned out in advance... they are meant to be like a "random" drug test.
That’s why it's necessary to invoice the costs of the drug tests directly to your employer... and NOT to you.
This way you don’t have to worry about "NOT having the funds" to pay for your drug tests…
Hopefully your employer will pay for your entire Follow-up Testing Plan… but if they want you to help cover the costs of the drug tests, then they might deduct the amount from your paycheck.
Keep in mind that you will also be enrolled in their normal Random drug and alcohol program… along with all the other drivers in the company.
Typically an employer will automatically pay for Random and Pre-Employment drug tests… but NOT necessarily your Follow-up Testing Plan.
Your Federal drug violation stays inside the Clearinghouse for 5 years from the beginning of your violation or until you complete STEP 6… which ever is LATER or takes LONGER.
If you have any questions, feel free to contact me anytime.
Dr. Kurt Meininger 678-925-1878.. or email... drkurtmeininger@gmail.com