Get Ready, Get Set…and Go!
The January 6, 2020 Implementation and compliance date for the FMCSA Drug and Alcohol Clearinghouse is less than 90 days away. Below is some information and a checklist for making sure you are on track for January 6, 2020:
- REGISTER NOW – Register in the Clearinghouse by visiting: https://clearinghouse.fmcsa.dot.gov/register
- The Clearinghouse website provides good resources to guide you through the registration process, including step by step instructions for the employer registration process. https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Employer-Instructions
- Designate and Invite Assistants who can perform functions in your Clearinghouse account. Guidance is available at: https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Assistant-Instructions
- Decide whether you are going to perform the required Clearinghouse functions of reporting driver violations and return to duty information and conducting queries on your own OR designate WFQA as your C/TPA to report and/or query on your behalf. If you want WFQA to be your designated C/TPA, you can do so when you register in the Clearinghouse or add it at a later time. You do not have to designate or identify WFQA as your MRO. WFQA has registered as an MRO and will automatically report all verified positive, adulterated and substituted drug tests, as well as “shy bladder: refusals to test” on your drivers to the Clearinghouse.
- The Clearinghouse Registration process will interface with your FMCSA portal account and you should link the two, especially if you have multiple US DOT numbers under your corporate structure.
- SETUP for procedures and processes for Clearinghouse reporting and queries
- Integrate the requirement for conducting a full Clearinghouse Query as part of your on-boarding/hiring process, including notifying all applicants that they must register in the Clearinghouse in order for the required pre-employment query to be conducted.
- Ensure that driver CDL# (with state of issuance) is used for all DOT drug and alcohol tests as the employee ID#.
- Develop and obtain driver signatures on a limited query consent form. The limited query consent form should specify how frequently you intend to conduct limited queries of the Clearinghouse (must be at least annually) and the length of time that the consent is effective (e.g.; 1 year, 5 years, tenure of employment, etc.). A sample limited consent form is available at: https://clearinghouse.fmcsa.dot.gov/Resource/Index/Sample-Limited-Consent-Form
- Develop procedures for compiling and reporting the DOT violations information you are required to report to the Clearinghouse within 3 days of the event. If you are having WFQA report this information on your behalf, coordinate how the information will be made available to WFQA for reporting.
- Purchase Query Plans, beginning November 2019. You must be registered in the Clearinghouse in order to purchase the queries, which are $1.25 per query. You must purchase queries—not WFQA or another agent you designate. Employers may make multiple purchases of queries as needed. General guidance is to purchase enough queries to meet your requirements in a calendar year. For example, if you have 100 drivers and you anticipate hiring 50 new drivers over the course of a year, you should purchase a query plan of at least 150. The queries purchased do not expire; you can purchase additional queries at any time. See: https://clearinghouse.fmcsa.dot.gov/Resource/Index/Query-Plan for more information.
- GO LIVE January 6, 2020. In the meantime, GO EXPLORE the FMCSA Clearinghouse website. It has excellent guidance, Q & A’s and resource documents. https://clearinghouse.fmcsa.dot.gov