December 9, 2019

Required DOT Drug/Alcohol Clearinghouse Begins January 6

New Department of Transportation Drug and Alcohol Clearinghouse Coming January 6, 2020

Cities employing CDL drivers will be required to participate in the new Department of Transportation (DOT) Drug and Alcohol Clearinghouse. The clearinghouse is a national database pertaining to violations of the DOT drug and alcohol testing program for holders of CDLs. Beginning January 6, 2020, cities employing DOT drivers will be required to query the clearinghouse for drug and alcohol violations for current and prospective employees before permitting them to operate a commercial motor vehicle. During the first three years, you must complete both the manual inquiries with prior employers (to meet the three-year timeframe) as well as the new electronic clearinghouse query. Once three years of violation data are stored in the clearinghouse, employers will only be required to perform an electronic inquiry through the clearinghouse.

Under the regulation, the city must create an employer account and designate a clearinghouse administrator. The administrator can designate assistants to help with input of clearinghouse requirements, including reporting of violations and running required inquiries. The city can also choose to utilize a third-party administrator to maintain reporting and inquiry compliance but there is no requirement to do so. Regardless of whether the city decides to keep the responsibility in-house or use a third-party administrator, the clearinghouse administrator must ensure all required reports and inquiries are completed.

Prior to January 6, 2020:

  • Set up the employer clearinghouse account here. For information and a step-by-step guide about registration, click here.
  • Once your clearinghouse account is created, perform an electronic inquiry of all current DOT employees through the clearinghouse.
  • Ensure you have up-to-date drug and alcohol testing information on all DOT employees for the last three years. If they have been employed with the city less than three years, ensure you have the required information from prior employers to satisfy the three-year requirements under 49 CFR Part 391.23(e).
  • If any records indicate an employee has an unresolved drug and alcohol violation, contact your city attorney. An unresolved drug or alcohol violation may require the city to prohibit the DOT employee from driving commercial motor vehicles, but no adverse employment action should be taken without the advice of your city attorney.

From January 6, 2020 through January 6, 2023:

  • Perform annual checks of current city DOT employees through both the clearinghouse and traditional manual inquiries for the three-year time frame.
  • Perform checks through both the clearinghouse and traditional manual inquiries for the three-year time frame for prospective DOT employees following an offer of employment conditioned on the performance of the background check.
  • If any record indicates the employee has an unresolved drug and alcohol violation, contact your city attorney. 
  • Report drug and alcohol violations to the clearinghouse. 


On or after January 6, 2023:

  • Manual inquiries will no longer be required for current or prospective DOT employees.
  • Perform annual checks of current DOT employees through the clearinghouse.
  • Perform checks through the clearinghouse for the three-year time frame for prospective DOT employees following an offer of employment conditioned on the performance of the background check.
  • If any record indicates the employee has an unresolved drug and alcohol violation, contact your city attorney. 
  • Report drug and alcohol violations to the clearinghouse.

The DOT has compiled a thorough frequently asked questions page to assist with compliance. However, KLC is also here to help. Please contact Courtney Risk Straw, Personnel Services Attorney, or Andrea Shindlebower Main, Personnel Services Manager, with any questions.