Many commercial drivers hear about Step 6 in the FMCSA Clearinghouse process and get nervous. You might have thought: “I can’t return to work until Step 6 is done.”
Here’s the truth: Step 5—not Step 6—is the key milestone for returning to duty (RTD). Step 6 is important, but it’s primarily administrative handled by your employer ONLY, not your SAP.
Understanding the difference can save time, reduce confusion, and get you back on the road faster.
Understanding the SAP and Clearinghouse Process
After a drug or alcohol violation, the FMCSA requires CDL drivers to complete the Substance Abuse Professional (SAP) process. This ensures safety-sensitive drivers are cleared to return to duty.
The process is tracked in the Clearinghouse, and it involves multiple steps:
- Driver Selects SAP – Choose a DOT-qualified SAP.
- SAP Initial Assessment – Evaluation of the violation.
- SAP Recommendation – Education or treatment plan prescribed.
- Driver Completes Program – Successfully finish the recommended steps.
- SAP Follow-Up Evaluation – SAP confirms completion and readiness for RTD testing.
- Employer Follow-Up Testing Plan (Step 6) – Employer receives the testing plan and reports only the LAST TEST in the Clearinghouse.
Step 5 vs Step 6: What Drivers Need to Know
The biggest misconception: drivers must wait for Step 6 to return to work.
- ✅ Step 5 is the real goal. Once you complete the SAP follow-up evaluation, you can take your Return-to-Duty (RTD) test.
- ✅ Step 6 is administrative. It ensures your employer services your follow-up testing plan correctly.
Bottom line: Complete Step 5, which is a negative RTD test, and you’re legally cleared to resume safety-sensitive duties. Step 6 does not hold you back.
Who Handles Step 6
| Role | Responsibility |
| Driver | Complete all required follow-up tests as per SAP plan. |
| SAP | Prescribes follow-up testing, monitors compliance, conducts evaluations. |
| Employer / C/TPA / DER | Reports completion of Step 6 in the Clearinghouse and ensures follow-up testing plan is implemented. |
Step 6 is not the driver’s responsibility—it’s between your employer and their testing site and/or C/TPA (Consortium/Third Party Administrator).
Common Step 6 Confusions
Even when drivers complete all tests, delays can happen because:
- The employer hasn’t updated the Clearinghouse.
- Communication gaps when moving between employers.
- Misunderstanding that Step 6 is required before RTD.
- C/TPA’s or testing sites requesting the testing plan from the SAP without revealing who the employer/DER is. SAP Reports Direct to DER
Tip: Focus on Step 5. Step 6 will follow automatically if all requirements are met.
FAQs About Step 6
Q1: Do I need to complete Step 6 before returning to work?
A: No. Step 5 completion which is a negative RTD test is required.
Q2: Who reports Step 6?
A: Only the employer or C/TPA/DER reports it.
Q3: Can Step 6 delay my return to work?
A: No, as long as Step 5 is completed, you’re set.
Q4: How long does Step 6 follow-up last?
A: Follow-up testing can last 12–60 months but runs in the background while you’re working.
Step 5 Is Your Goal—We’ll Help You Reach It
Don’t let misconceptions about Step 6 hold you back. Your priority is completing Step 5, which is passing your RTD test. Step 6 will take care of itself.
At Delivered2Choices, we help drivers:
- Navigate the SAP and Clearinghouse process.
- Ensure proper follow-up testing compliance.
- Avoid unnecessary delays in returning to work.
Step 5 is your goal—let’s get you there.
👉 Contact Delivered2Choices today to get clear guidance, ensure compliance, and return to safety-sensitive duties confidently.
