The SAP reports two return-to-duty milestones
For an FMCSA-regulated CDL driver, the designated SAP reports the date of the initial SAP assessment and, later, the date on which the SAP determines that the driver has successfully complied with the required education or treatment and is eligible for return-to-duty testing.
FMCSA's Clearinghouse FAQs state that these entries are the SAP's responsibility. If the dashboard is waiting at one of these SAP milestones, the appropriate first contact is normally the designated SAP, not the testing laboratory.
The negative RTD result is reported by the employer or authorized C/TPA
Once the SAP has made the driver eligible for RTD testing, the next milestone involves the DOT return-to-duty test. Under 49 CFR 40.305, the employer must ensure the test is completed before allowing a return to safety-sensitive functions.
For Clearinghouse reporting, the employer reports the negative RTD test result. A properly authorized C/TPA may perform reporting functions on an employer's behalf. Drivers should not attempt to treat an independently purchased drug test as the federal RTD event. Drivers without a current or prospective employer should read return-to-duty without an employer because FMCSA has a specific C/TPA procedure for that situation.
When Prohibited changes to Not Prohibited
FMCSA states that reporting the required negative RTD test result changes the driver's Clearinghouse status from Prohibited to Not Prohibited. That means the unresolved violation no longer prohibits the driver from FMCSA-regulated safety-sensitive functions through the Clearinghouse.
It is not a guarantee that an employer will place the driver back into a driving job. DOT rules leave that personnel decision to the employer. It also does not mean the follow-up testing obligation has been completed. See Prohibited versus Not Prohibited for the distinction.
Follow-up completion is a later Clearinghouse entry
After the driver resumes safety-sensitive duty, the SAP's follow-up testing plan applies. 49 CFR 40.307 requires at least six unannounced tests during the first 12 months of safety-sensitive duty, and the SAP may require testing for longer.
FMCSA identifies the employer as responsible for entering the date on which the driver's follow-up testing plan has been successfully completed. Follow-up testing is separate from random testing, and the actual schedule must not be disclosed to the driver.
If the status display appears inconsistent with what has already occurred, identify the exact missing milestone before contacting the party responsible for reporting it.