U.S. DOT Substance Abuse Professional (SAP) FAQs

The U.S. DOT is allowing SAPs to provide remote assessments at their discretion during the COVID crisis. These remote evaluations will only be allowed as long as the Department of Health and Human Services (HHS) determines there is a public health emergency or until December 31, 2021, whichever is sooner. Read the full statement.

Below are answers to many of the frequently asked questions we receive regarding the U.S. DOT Substance Abuse Professional (SAP) Qualification credential and training. If you still have questions, please call 703-741-7686 and select option # 5 for SAP, or email Richard Goodman, SAP Administrator, at [email protected]

U.S. DOT SAP Eligibility FAQs

Who is required to engage in qualification training and education to be a SAP?

Anyone who wants to do evaluations and provide treatment recommendations to a U.S. DOT-covered services member must be qualified through education and testing to be a SAP.

What credential or license must I have to pursue a SAP qualification?

To qualify to be a DOT SAP, you must have one of the following credentials:

  • Nationally certified* alcohol/drug abuse counselor through: 
    • NAADAC/NCC AP -  NCAC I, NCAC II, or MAC national credentials only; or
    • International Certification & Reciprocity Consortium (IC&RC) - ICADC or ICAADC national credentials only; or 
    • National Board of Certified Counselors (NBCC) – MAC national credential only. 

      Please note that state alcohol/drug abuse counselor credentials and licenses, and general counselor credentials and licenses (such as a LPc) are not accepted.
  • Licensed physician (Doctor of Medicine or Osteopathy)
  • Licensed or certified psychologist
  • Licensed or certified social worker
  • Licensed or certified employee assistance professional
  • Licensed or certified marriage and family therapist

What knowledge is expected of a person qualified to be a SAP?

You cannot be a SAP unless you have knowledge of and clinical experience in the diagnosis and treatment of substance abuse-related disorders. You cannot be a SAP without understanding how the SAP role relates to the special responsibilities employers have for ensuring the safety of the traveling public. Nor can you be a SAP unless you are well informed about Part 40, pertinent DOT agency regulations, these SAP guidelines, and any significant changes to them. It is important to note that your degrees and certificates alone do not confer to you these knowledge requirements.

Do I have to take a test to be qualified as a SAP?

Following completion of your training, you must pass an examination given by a nationally recognized professional or training organization that comprehensively covers all the elements required for the qualification training.

NAADAC provides a 100-question initial SAP Qualification examination and a 25-question renewal SAP Qualification examination.


I took my qualification test from another DOT/SAP company. Can I submit my information to NAADAC to be added to NAADAC’s SAP Provider Directory?

No. Only persons who have completed the NAADAC DOT SAP training and pass the qualification or requalification test can be added to the NAADAC SAP Provider Directory.

U.S. DOT SAP Practice FAQS

Who are the DOT-covered employees under DOT Testing Regulation 49 CFR Part 40?

What is and how do I register with the Federal Motor Carrier Safety Administration: Drug & Alcohol Clearinghouse?

The Clearinghouse, a web-based system found at https://clearinghouse.fmcsa.dot.gov, will provide Federal Motor Carrier Safety Administration (FMCSA) and employers of commercial motor vehicle (CMV) drivers with the necessary tools to identify drivers who are prohibited from operating CMVs due to DOT drug and alcohol program violations.

All SAPs who work with or plan to work with covered employees under the Federal Motor Carrier Safety Administration must register with the Clearinghouse.

Click here to learn more about the Clearinghouse and how to sign up.

When I list my SAP qualification anywhere, can I list it as DOT/SAP or just SAP?

The SAP is a qualification and not a certification. You can only list yourself as a SAP and cannot list yourself as a DOT/SAP, as the DOT did not certify or qualify you.

A DOT-referred client began their evaluation with me but did not complete the evaluation. They return to me six months later and want to complete their evaluation, starting where they left off. Can they complete their evaluation where they left off?

No. A new evaluation will need to be initiated.

If a person starts their DOT assessment with another SAP, and then contacts me – a different SAP – to complete a new DOT evaluation, is this acceptable?

No. Covered DOT employees may not shop around for a SAP. Once they start an evaluation with a SAP, they cannot transfer to another SAP.

Can I do SAP assessments using telehealth-related technology or video conferencing technology?

Based on the latest information posted on the U.S. Department Of Transportation’s website concerning remote telehealth and remote evaluations, it appears that the option to provide remote services will continue for a while longer.

On February 28, 2022, DOT published a notice of proposed rulemaking (NPRM) that, among other things, proposed to allow SAPs to conduct assessments and evaluations either in-person or remotely provided that certain requirements are met. The proposed requirements include criteria that are intended to ensure that the SAP can objectively evaluate an employee’s non-verbal and physical characteristics that might be indicative of problems associated with alcohol abuse and/or drug use. Those criteria are based on and consistent with those in the currently applicable Statement of Enforcement Discretion issued by ODAPC. The current enforcement discretion extends through December 31, 2022. To provide consistent program administration for SAPs and affected employees, ODAPC has determined to continue this enforcement discretion until the effective date of any final ruling on the NPRM. 

NAADAC recommends that you periodically review the Department Of Transportation’s statement of enforcement for the latest status of utilizing telehealth options for SAP services.  

For the latest notices about using remote telehealth services, check the DOT Drug & Alcohol Testing Statement of Enforcement Discretion for Substance Abuse Professionals | US Department of Transportation page for updates.

The employee is stating that they have a medical marijuana card for medical purposes (i.e., anxiety and pain). Does the DOT recognize and allow the employee’s use of medical marijuana? Recreational marijuana?

No, the DOT will not allow any covered employees to use any form of marijuana. Please read the following DOT notices regarding marijuana:

Can an employee come to me for a SAP evaluation without a referral from a DRS?

No, an employee cannot come to you without  paperwork showing who the DRS is. The DRS is your employer contact person.  The DRS is the person receiving updates and return-to-duty status from you.

What happens when the employee needs to get a SAP evaluation and complete the SAP’s recommendations – and the employee has left their previous place of employment and is starting at a new place of employment?

The SAPs evaluations and treatment recommendations stand.  The reports and recommendations will be sent to the new DRS as they will have to make sure the covered employee completes the SAP recommendations prior to putting the employee into a safety-sensitive position.