How the DOT Return-to-Duty Process Has Changed Since 2020: What Employers & Drivers Must Know

Since 2020, the DOT Return-to-Duty process has undergone significant updates, reshaping how commercial drivers and employers manage substance abuse compliance. These changes were driven by evolving federal regulations, the integration of the FMCSA Clearinghouse, and an increasing shift toward telehealth services.

Let’s dive into what’s new—and what you must do in 2025 to remain compliant.

Key Changes to the DOT Return-to-Duty Process Since 2020

1. Mandatory FMCSA Clearinghouse Reporting

Since January 2020, all DOT drug and alcohol violations must be reported in the FMCSA Drug & Alcohol Clearinghouse. Employers are now required to:

• Perform full queries before hiring a CDL driver.

• Conduct annual limited queries.

• Immediately report any drug/alcohol violations.

Keyphrase used: DOT Return-to-Duty process

2. CDL Downgrades for Prohibited Drivers (2024 Update)

As of November 2024, drivers in “prohibited” status will face automatic CDL downgrades if not enrolled in a DOT SAP program. This intensifies the urgency for drivers to begin the Return-to-Duty process immediately after violation.

Read about the CDL downgrade rule update

3. Telehealth SAP Evaluations

One of the biggest innovations post-2020 is the availability of online SAP evaluations. These sessions are DOT-compliant and help drivers:

• Begin evaluations faster

• Save on travel expenses

• Access SAP professionals nationwide

This change makes the DOT Return-to-Duty process more accessible than ever.

What Employers Must Do Differently in 2025

• Maintain up-to-date Clearinghouse records

• Verify SAP completion before allowing a driver to return

• Educate drivers on the consequences of violations and the steps in the RTD process

What Drivers Must Know in 2025

• You cannot return to safety-sensitive duties until you:

  • Complete a DOT SAP evaluation

  • Finish required treatment

  • Pass a return drug/alcohol test

Delays can now result in license downgrades and longer reentry time.

Conclusion: Stay Ahead of the Changes

The DOT Return-to-Duty process is no longer what it was in 2020. With new policies, stricter enforcement, and modern tools like telehealth, both employers and CDL drivers must stay informed and proactive.

Suggestions:

• DOT SAP Program – AACS Counseling

• Return-to-Duty Evaluations – SAP Evaluation

  • FMCSA Clearinghouse