The below update was sent out by the Federal Motor Carrier Safety Administration on September 1, 2021.

Use Revised Custody and Control Form

As of August 30, 2021, DOT-regulated employers and their service agents, including medical review officers (MROs), must use the revised Federal Drug Testing and Custody and Control Form (CCF). Request the updated CCF from your HHS-certified laboratory today.

The DOT’s Office of Drug and Alcohol Policy and Compliance (ODAPC) sent out two messages this month—on August 10, 2021 and August 24, 2021—with detailed information that employers and their service agents who help with the drug testing programs need to know. Make sure that your tests don’t get canceled!

Please note that while most of the changes adopted in the revised CCF were made to accommodate the use of oral fluid specimens for the Federal drug testing program, oral fluid drug testing is not authorized in DOT’s drug testing program and therefore results of these tests are not entered in the Drug and Alcohol Clearinghouse.

Revised CCF Includes Data Field for Driver CDL Information

As a reminder, social security numbers (SSNs) or employee identification numbers (EINs) should not be used to enter a driver’s violation in the Clearinghouse; the Clearinghouse final rule states that users must enter the driver’s commercial driver's license (CDL) or commercial learner's permit (CLP) number and State of issuance.

The revised CCF includes the addition of “CDL State and No.” to the line in Step 1C that captures donor identification information. Including a driver’s CDL number and State of issuance here for all FMCSA-regulated tests assists MROs in reporting drug and alcohol violations in the Drug and Alcohol Clearinghouse.

Reminders for MROs

Are Your Qualifications Current?

To remain eligible to act as an MRO in the DOT drug testing program, you have a continuing obligation to comply with the MRO qualification requirements in 49 CFR § 40.121, including credentials, basic knowledge, qualification training, requalification training, and documentation. Failure to comply with these requirements, at any time, will render you unqualified to perform MRO services for the DOT program.

Reporting Violations

MROs are required to report the following violations in the Clearinghouse:

  • Verified positive controlled substances test results
  • Refusal-to-test determinations (i.e., adulterated, substituted and/or insufficient specimen with no legitimate medical explanation) for controlled substances tests

These must be reported within two days of making the verification or determination. The MRO must report any changes of a verified drug test within one business day of making any changes to the reported results.


Questions? Comments. Let us know.

Please join us for our upcoming webinar, Thursday, April 6th – What Employers Need to Know About California’s New Drug Testing Laws