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Can I Complete Step 6 of the SAP Program Without an Employer?

  • Writer: Dee Dee
    Dee Dee
  • Aug 5, 2025
  • 4 min read

Updated: Aug 8, 2025

Yes — it is possible for a truck driver to complete Step 6 of the SAP (Substance Abuse Professional) return-to-duty process without having an employer, but it takes some work and understanding of the system.


What Is Step 6?

Step 6 is when a driver takes a DOT return-to-duty drug and/or alcohol test — directly observed — after completing the SAP’s recommended education and/or treatment.

This test must be:


  • Scheduled by an employer, and

  • Entered into the Clearinghouse as part of the return-to-duty process.


But What If You Don't Have an Employer?

Since Step 6 must be administered by an employer (or someone acting in that role), here are your 2 options:

✅ Option 1: Register as an Owner-Operator

You can act as your own employer if you:

  • Register with FMCSA as a motor carrier (get a DOT number).

  • Create a Clearinghouse account as an employer.

  • Work with a Consortium/Third Party Administrator (C/TPA) to handle your compliance responsibilities (including random testing, recordkeeping, etc.).

  • Use a DOT-approved collection site to take your return-to-duty test under direct observation.

Once you pass that test, the employer side of your Clearinghouse account (which you control) can mark the Step 6 as complete. Important Notes: Since you’re already in the Clearinghouse as a driver, you would only need to add an employer account if you go this route. Keep your driver account (no changes). Also register as an employer in the Clearinghouse (using your DOT number). Link the two roles in your login. You’ll designate your C/TPA in the employer account so they can handle compliance


✅ Option 2: Use a C/TPA Offering Step 6 Services

Some SAP professionals or C/TPAs offer a paid service where they:

  • Temporarily act as your "employer of record" for the purpose of Step 6.

  • Schedule and manage your return-to-duty test.

  • Report the result to the Clearinghouse properly.

You’ll need to:

  • Provide your driver Clearinghouse account and allow them to report.

  • Pay their fee

This lets you complete Step 6 without owning a company or registering with FMCSA.


👇 So Just to Recap

✅ To act as your own employer and complete Step 6, there are 3 things you need to do:

1. Get a U.S. DOT Number


You can apply online here:

Choose: “Register as a Motor Carrier (with a USDOT Number only)”

Follow the steps. You’ll need:


  • Your name or business name

  • Mailing address

  • SSN or EIN

  • Type of operation: choose "Interstate" or "Intrastate" based on what you plan to do

  • You can select “Non-Hazmat” and “Private Carrier” for now, if you’re not hauling yet

It’s free to get a DOT number if you’re not applying for operating authority (MC number).

2. Register in the FMCSA Drug & Alcohol Clearinghouse as an Employer

Create a Clearinghouse account as an employer. Your employer account is where you'll need your DOT number.


3. Enroll in a C/TPA (Consortium/Third Party Administrator)

This is required for owner-operators to manage:

  • Pre-employment tests

  • Return-to-duty tests

  • Randoms

They can help handle your Step 6.


✅ Alternative Option 2 (If You Don’t Want a DOT Number)

If you don't want to register as an owner-operator or get a DOT number, your only real option is to pay a legit C/TPA or SAP consultant who will act as your “employer of record” just for Step 6.

They’ll:

  • Order the test

  • Report the result to the Clearinghouse

Recommended C/TPAs (That Handle Return-to-Duty):

Here are a few legit services that can help you either as an owner-operator or without a DOT number:


Option A: CleanFleet

Services: SAP return-to-duty, C/TPA enrollment, Clearinghouse help

Will work with owner-operators or people trying to finish SAP without an employer

Phone: 503-479-6082


Specializes in SAP return-to-duty

Offers a "no employer" option for Step 6

Can act as employer of record to schedule and report the test



Offers SAP program help, RTD test, and C/TPA services nationwide

Phone: 866-566-0261


Here's a professional but straightforward email you can send to a SAP service or C/TPA provider to help you complete Step 6 of the SAP return-to-duty process — even if you don’t currently have an employer:


Subject: Help Completing Step 6 of SAP Program Without an Employer

Hi [Name or Company Name],

I’m reaching out because I’m currently in the SAP return-to-duty process and need help completing Step 6 — the observed drug/alcohol test — but I do not have a current employer.

I’m looking for a service that can either:

  • Act as an employer of record just for Step 6, or

  • Assist me as a new owner-operator, if that’s required.

I’ve already completed my SAP-recommended treatment/education, and I’m ready to move forward with the return-to-duty test and Clearinghouse reporting.

Can you let me know if you offer this service, what the cost would be, and what the next steps are?

Thank you for your time,

[Your Full Name]

[Phone Number]

[Email Address]

(Optional: Clearinghouse ID or CDL number) Here are several more legit, FMCSA-compliant C/TPAs (Consortium/Third-Party Administrators) that specialize in SAP return-to-duty testing, owner-operator compliance, and Clearinghouse reporting. Most of these can help you finish Step 6 even without a current employer, either by:

  • Acting as your employer of record, or

  • Helping you register as an owner-operator.


✅ Additional Legit C/TPAs to Contact:


TeamCME

Phone: (844) 832-6237

Services: DOT testing, SAP RTD coordination, C/TPA management, nationwide network

Why contact: Known for working with individual drivers and small carriers; very responsive and DOT-compliant


Consortium Pool

Phone: (405) 601-2549

Services: SAP return-to-duty help, owner-operator C/TPA services, FMCSA Clearinghouse support

Why contact: Very transparent pricing and tailored to solo drivers


FleetScreen (part of DISA Global Solutions)

Phone: (888) 301-2266

Services: National coverage, DOT compliance, return-to-duty and random testing, employer/driver setup

Why contact: Works with companies and individuals, large provider with good FMCSA experience


💡 Tip:

When you reach out to any of these, use the email I drafted earlier — or ask them directly:

“Can you act as the employer to schedule and report my return-to-duty test if I don’t currently have a job?”


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