Yes. A DOT substance abuse professional (SAP) evaluation can be conducted remotely. Under 49 CFR Part 40, the SAP may conduct both the initial evaluation and the follow-up evaluation either in person or remotely.
A remote evaluation is not a phone appointment, questionnaire or recorded video. Part 40 requires real-time audio and visual interaction of sufficient quality for the SAP to obtain the information they would gather during an in-person meeting. The technology must also provide appropriate security for confidential communications. The SAP must remain within any geographic limits that apply to the professional credential that qualifies them to perform SAP work.
What Part 40 requires
The initial SAP evaluation is a comprehensive assessment and clinical evaluation. The SAP determines what education and/or treatment is appropriate after the DOT drug or alcohol violation.
Part 40 permits the SAP to conduct that evaluation face-to-face in person or remotely. For a remote evaluation, the technology must allow real-time audio and visual interaction. The connection and video quality must be sufficient for the SAP to see and hear the information they would normally obtain during an in-person evaluation.
The follow-up evaluation may also be conducted remotely under the same standard. At that stage, the SAP reviews the driver’s participation in the recommended education and/or treatment and determines whether the driver has demonstrated successful compliance.
A phone-only interview, online questionnaire, prerecorded video or automated assessment does not meet the remote face-to-face standard.
Remote video: what to verify before you book
Remote SAP evaluations are expressly permitted by Part 40, but that does not mean every person advertising an online SAP program is qualified to perform one.
Before booking, ask:
- Are both the initial and follow-up evaluations conducted live by the DOT-qualified SAP over two-way audio and video?
- What professional license or credential qualifies you to act as a DOT SAP?
- Does that credential allow you to conduct a remote evaluation for someone located in my state?
- Are you registered in the FMCSA Clearinghouse so I can designate you?
- Are education, treatment, follow-up evaluation and other charges included in the quoted price or billed separately?
The choice between an in-person and remote SAP evaluation is ultimately the SAP’s professional decision. Part 40 does not give the employee or employer the right to require the SAP to use one format rather than the other.
You can check the federal rules and guidance on the [ODAPC website]\(https://www.transportation.gov/odapc).
Parts of the SAP program that can happen online
- Clearinghouse steps: For an FMCSA-regulated CDL driver, the driver designates the SAP in the Clearinghouse. The SAP accepts the designation and reports the date of the initial assessment and, later, the date the driver is eligible for return-to-duty testing.
- Education: Depending on the SAP’s recommendation, an education program may be available online. Do not substitute a course you found yourself for the education or treatment prescribed by the SAP.
- Treatment: Treatment may sometimes be delivered remotely if it is appropriate, available and consistent with the SAP’s recommendation and the treatment provider’s requirements.
- Scheduling and paperwork: Appointments, intake information and other administrative steps are commonly handled electronically.
DOT testing itself is not an online step. If a drug test is required for return-to-duty or follow-up testing, the collection must be directly observed under Part 40. A SAP can also prescribe alcohol follow-up testing where appropriate.
After the SAP determines that the driver has successfully complied and is eligible for return-to-duty testing, the employer is responsible for ensuring the required return-to-duty test is completed before allowing the driver to resume safety-sensitive work. For FMCSA drivers, the employer or authorized C/TPA reports the negative return-to-duty result to the Clearinghouse.
Checking an online SAP before you pay
A remote SAP must meet the same DOT qualification requirements as an in-person SAP. That includes holding one of the professional licenses or credentials permitted by Part 40, having the required knowledge and clinical experience, completing SAP qualification training, passing the required examination and completing at least 12 professional development hours during each three-year period.
For FMCSA-regulated CDL drivers, the SAP also needs to be registered in the Clearinghouse so the driver can designate them.
Remote practice has another important limitation. A SAP must comply with the geographic restrictions of the professional credential that qualifies them to act as a SAP. Advertising service in every state does not by itself establish that the SAP’s credential permits remote practice everywhere.
Part 40 also restricts treatment referrals that create a financial conflict of interest. Subject to specific exceptions in the rule, a SAP cannot refer a person to the SAP’s own private practice or to a provider in which the SAP has a financial interest or from which the SAP receives payment.
Our guide on how to find a DOT-qualified SAP explains the qualification checks, while what to expect from a DOT SAP evaluation covers the evaluation itself. Before paying, compare what the quoted fee actually includes. The usual components are explained under SAP evaluation cost. You can also compare providers and coverage in the DOT SAP program directory.
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