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Part 1 Webinar Q&A: "30 Days In – Status of the Drug & Alcohol Clearinghouse"

Did you have a chance to attend the webinar, “30 Days In – Status of the Drug & Alcohol Clearinghouse”? We received more questions than we had time to answer in the allotted time frame, so our presenter for the webinar, Dave Osiecki of Scopelitis Transportation Consulting, answered them below in this Q&A-style blog post. If you weren’t able to join the live webinar, don’t worry – you can watch it on-demand anytime!

Note: Part 2 of the Q&A will be available on Tuesday, February 18th

Question: I've purchased 200 queries and they never showed up in my company account. I never received a receipt, but the money came out of our account, then my D&AC said I had a balance of 0 queries. How do I rectify this?

Answer: I’d suggested contacting FMCSA at clearinghouse@dot.gov so that they can research the issue. 

Question: Can you explain how to do a bulk upload? The instructions are vague.

Answer: By clicking on the “employers” tab at this link https://clearinghouse.fmcsa.dot.gov/Learn, you can download instructions sheets for both limited and full queries. Also available under this tab is the limited query template file, which is available for download. 

Section 1: Query Notifications

Question: If we run a full query, will we be notified at the time of query, if the CDL driver has not enrolled in the clearinghouse ?

Answer: No, unfortunately carriers are only notified if the CDL information they entered cannot be verified. Carriers should take a proactive approach and ask the driver if they’re registered and help them register if they haven’t already. 

Question: Regarding full queries: I am not receiving a notification email once the driver has responded to the consent request. Do you know why I am not receiving a notification email?

Answer: No. I would encourage you to check your settings or contact FMCSA at clearinghouse@dot.gov if you feel there is a system problem that is preventing notification. 

Question: What's the reason for many full queries staying in pending for a long time till now? Is it a Clearinghouse system issue and when is it going to be fixed? 

Answer: FMCSA has indicated that the primary reason a full query will remain pending is that the driver has yet to log on to consent to the full query. If the driver cannot see the query request on his or her dashboard, you should cancel the query and resubmit by entering the drivers CDL information exactly the same way the driver entered it when he or she registered. Here is a link to instructions for a driver to grant consent to queries. https://clearinghouse.fmcsa.dot.gov/Resource/Index/Consent-Requests-Driver

Question: Is there any turnaround time between registration and receiving / signing a consent for a full query? How many hours should be between the driver has registered and received the consent for a signature? The point is that many drivers register and do not receive a consent via this system and their queries are staying in pending after Jan 22., in spite of issues claimed to be fixed.

Answer: See response above

Question: What's the routine for getting long pending queries completed? What steps should be taken if the drivers do not receive the consent to sign? 

Answer: See response above

Question: Is there any deadline for pending queries to be completed? As well as a grace period deadline?

Answer: Full queries must be completed before the driver is allowed to operate a CMV requiring a CDL. If you experienced technical difficulties from Jan 6 to Jan 22 and hired a driver without first conducting a full query, you must now complete the query process. Drivers may continue to perform safety sensitive functions while the query is completed. See FMCSA’s FAQ on the topic. https://clearinghouse.fmcsa.dot.gov/FAQ/SearchFAQs?searchWord=technical

Question: Is it considered as non-compliance by a hiring company if the registered driver did not receive the consent to sign and his query stays in pending? May he still be hired and drive while waiting for the query to be completed by the system?

Answer: You may hire a driver while a query is pending but he or she may not be allowed to operate a CMV requiring a CDL until the query results have been delivered and reviewed. 

Question: Do you need to have a FMCSA portal account in order to create a Clearinghouse account? Will you still be able to conduct queries if your account is not linked with the FMCSA portal?

Answer: You can register as an “employer without a portal account” and then select “I will obtain my USDOT number later,” as shown in step 14 at this link. https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Instructions-Employer-without-Portal

 If  you chose “my company has a USDOT Number” for Step 13, the system will direct you to the portal.

[Note: In late January, FMCSA published an FAQ about linking portal accounts after the fact, which says the Agency has “temporarily deactivated” this feature while they make updates to the functionality. https://clearinghouse.fmcsa.dot.gov/FAQ/SearchFAQs?searchWord=portal]

Question: Can the system send a notice when a query has been completed? Or do we just need to keep checking for it?

Answer: We are aware of reports of notifications not being issued. Check which email was used to register for the Clearinghouse. This is typically the email address to which notifications are sent. Unfortunately, current best practice is to check your Clearinghouse dashboard regularly to see a new query is available. 

Question: What's the routine for getting long pending queries completed? What steps should be taken if the drivers do not receive the consent to sign? 

Answer: Full queries are released once consent is granted. For problems with drivers not receiving consent requests, see above. 

Question: Is there any deadline for pending queries to be completed? As well as a grace period deadline?

Answer: See response above

Question: Do you suggest doing the annual limited query monthly with annuals or once a year as a group?

Answer: This comes down to carrier preference. In our experience, carriers are working to align limited queries with current annual MVR practices. 

Question: I thought the employers would receive an email when a driver accepts the Query? I am not...I have to check my 3 DOT numbers several times a day.

Answer: See response above

Question: Can you hire someone before their query comes back? How long does the carrier have to get the pre-employment query back?

Answer: You may hire a driver while a query is pending but he or she cannot not be allowed to operate a CMV requiring a CDL until the query results have been delivered and reviewed.

Question: How many years can you make the limited query for?

Answer: Limited query consents can last for the length of employment, provided the limited query consent explicitly states such. Here’s a link to a sample consent form which allows you to stipulate how long the consent is good for. https://clearinghouse.fmcsa.dot.gov/Resource/Index/Sample-Limited-Consent-Form. You must run at least one query per year to be compliant. 

Question: We get questions from both employers and drivers asking how we (C/TPA or employer) can verify that a driver has registered? Is that only possible by performing a query?

Answer: Unfortunately, a carrier cannot tell whether or not a driver is registered via the Clearinghouse. 

Question: If I put a query out there and the driver isn't registered, will I need to send a new query when they register (full query)?

Answer: This should not be necessary. When the driver registers, provided the CDL information you entered matches that which the driver entered, they should see the query in the dashboard within a reasonable amount of time. 

Question: When requesting a pre-employment query, what is the longest it should take to get the results?

Answer: Pre-employment full queries should be available shortly after the driver logs in to his or her Clearinghouse account and grants consent to the query

Question: When you go on to request a full query does that trigger to send that request to the driver and then the query is finished once he signs it or do we need to go in and finish the process?

Answer: Once the driver grants consent, it will be available on the carrier’s dashboard. Once you access and review it, the process is complete. 

Question: If we do a full query and don't receive anything back from the driver, what is our next step and what is that timeframe?

Answer: Verify with the driver that he or she has received the consent request and granted it by logging into the Clearinghouse. If he hasn’t seen the consent request, see above for possible next steps. 

Question: If a current employee transfers into a driver position, am I required to run an inquiry in the clearinghouse?

Answer: Yes, if the driver is expected to operate a CMV that requires a CDL, you should conduct a full-query on the driver prior to allowing him or her to drive. 

Section 2: Carrier Registration Issues

Question: What happens when a trucking company has portal issues and cannot register? They need to hire drivers.

Answer: We suggest you register as an employer without a DOT number to enable you to conduct queries until the portal issues are rectified. After January 6, 2020, allowing a driver to operate a CMV for which a CDL is required without first obtaining a full query is a violation. Follow these steps to register without a portal account. 

You should register as an “employer without a portal account” and then select “I will obtain my USDOT number later,” as shown in step 14 at this link. https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Instructions-Employer-without-Portal

We are guessing that when you get to step 13, you chose “my company has a USDOT Number” which then directs you to the portal.

[Note:  In late January, FMCSA published an FAQ about linking portal accounts after the fact, which says the Agency has “temporarily deactivated” this feature while they make updates to the functionality.

 https://clearinghouse.fmcsa.dot.gov/FAQ/SearchFAQs?searchWord=portal ]

Question: I still can't link my portal account with my clearinghouse account because of the chooser issue. When will this be corrected?

Answer: More information needed. Not sure what the “chooser issue” is. 

Question: For companies who are having issues with their FMCSA portal and are still waiting for the FMCSA to get back to them. in order for us to register with the clearinghouse. Can we continue the hiring process without the clearinghouse for now without being penalized?

Answer: See response above 

Question: If a carrier registered as not having a portal account, will instructions be posted on how to connect the two later?

Answer: Yes. You can sign up for notifications here. https://clearinghouse.fmcsa.dot.gov/Home/Subscribe

Question: If a Company has been trying to register other employees for the Clearinghouse but cannot do so due to not being able to register for the FMCSA Portal, who can they contact? This has been an issue since you were able to register for the Clearinghouse. The Company has reached out to FMCSA numerous times and no one has helped or given us any feedback.

Answer: Unfortunately, FMCSA is currently working through a backlog of questions concerning Portal accounts and are working to help everyone as soon as they can. The portal help page is located here: https://ask.fmcsa.dot.gov/app/answers/detail/a_id/572

Question: We are staffing company and sole employer. We are registered in the Clearinghouse as an employer and perform the queries. Are our clients (who are motor carries/own the DOT number) required to register also, even though they employee no CDL drivers?

Answer: Please review FMCSA’s latest guidance document on motor carrier’s use of a staffing company’s drug and alcohol testing program. https://www.federalregister.gov/documents/2016/12/23/2016-30991/controlled-substances-and-alcohol-testing-responsibilities-of-commercial-driver-staffing-agencies

Section 3: Driver Registration

Question: Does each CDL driver have to register themselves or is the company supposed to register them?

Answer: Drivers will have to register themselves - but ONLY IF they are applying for a CDL job. Otherwise drivers DO NOT need to be registered

Question: Is there a way to figure out what way the drivers license should entered? Every state is different and it takes several attempts to figure it out.

Answer: For the purposes of the Clearinghouse, CDL information should be entered without special characters, dashes, etc. There is no single resource available that indicates whether or not a state will validate a CDL without a “leading 0.”

Question: Are employers responsible for enrolling already employed CDL drivers in the Clearinghouse?

Answer: All CDL drivers are already IN the Clearinghouse, but may not be registered. They will NOT need to be registered in the Clearinghouse unless they are applying for a new CDL job. You'll be able to perform the necessary limited query during the annual review process without the driver needing to be registered.

Question: Must we name a SAP or MRO on our clearinghouse, or can the driver use anyone of these that is registered?

Answer: Carriers are not able to designate an MRO or a SAP in the Clearinghouse. The driver can use any registered SAP. 

Question: Today we had 2 drivers try to verify their license information in Clearinghouse and an error said it was not valid. Is there still a problem like before with this process?

Answer: The verification problem has been corrected. The drivers should try again and be sure to enter their CDL information without any special characters, spaces or dashes. 

Question: How do the drivers get signed up?

Answer: Drivers who are applying for a CDL job need to register with the Clearinghouse. They just need to visit the FMCSA's Clearinghouse website and follow the instructions for CDL drivers

Driver registration instructions are available at this link: https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Driver-Instructions

Question: You mentioned when the driver registers...If driver's don't have to register, why would the leading zero affect the limited query?

Answer: The most likely problem if limited queries are coming back not validated is that the information was not properly entered by the carrier (e.g. wrong CDL Number, DOB, etc).

Question: We have CDL drivers as well as Non-CDL drivers who drive CMV straight trucks, but they are not required to have a CDL for them. Do they need to be in the Clearinghouse as well?

Answer: The Clearinghouse requirements do not apply to drivers who operate CMVs for which a CDL is not required, regardless of whether or not they have a CDL. 

Question: One of our drivers is unable to verify his CDL within the Clearinghouse. After speaking with the Arkansas State Department of Motor Vehicles, they communicated to us that Arkansas isn't participating in the Clearinghouse. Are states allowed to opt out? What are we supposed to do in this instance?

Answer: Arkansas’ state based testing database  does not feed data into, or pull data out of, FMCSA’s Clearinghouse. Inter- and intrastate motor carriers, and their drivers, are required to participate in the FMCSA Clearinghouse in addition to any state requirements. 

Question: If a driver registers with a TX License and then moves to New York, does their info automatically transfer when they move and get their new license?

Answer: Yes. The Clearinghouse utilizes the Commercial Driver’s License Information System (CDLIS) which is a pointer system that directs the user to the more recent, valid CDL information. 

Question: Can you please give an explanation on how drivers go about registering, so that we can instruct them?

Answer: The FMCSA's Clearinghouse website gives GREAT step-by-step instructions. Here's a link to that site: https://clearinghouse.fmcsa.dot.gov/Resource/Index/Registration-Driver-Instructions 

Question: To confirm, only AFTER they obtain the license can a license be validated. NOT while they are holding a permit?

Answer: A CLP holder will also be in the Clearinghouse, however it may take up to 10 days for it to be registered with the state

Question: How long does it take for an applicant to receive the consent form once they register?

Answer: Applicants should see the consent form within minutes after registering, provided they validated their CDL information during registration and that they validated exactly the same way as the employer did. See additional response above. 

Question: Do all my current drivers need to register in the Clearinghouse? 

Answer: Drivers only need to register for the Clearinghouse if they’ll need to consent to a full query (pre-employment or if a limited query returns results). 

Question: Is there anyone I can talk to if I am having problems registering?

Answer: FMCSA is currently working though a backlog and will return your email as soon as possible. If you’re having trouble with step in the process that requires linking your portal account, we recommend you register without linking the portal account for now and link it later. See response above. 

Section 4: Driver Consent

Question: How long does a driver have to give a company consent to perform the full query? 24 hours? Does the consent expire?

Answer: Consent requests do not expire. There is no time limit within which the driver must grant consent.

Section 5: Training / School Driver Registration / Query

Question: When is the appropriate time to query a driver that does not have a CDL but obtaining one as a result of our training?

Answer: The driver won't be in the Clearinghouse until AFTER they've received a CLP or CDL. There will be no record available before then. The carrier must obtain and review a full query on the driver before allowing him or her to operate a CMV requiring a CDL. 

Question: CDL schools are struggling with the Clearinghouse. For CDL permit holders who have no prior DOT driving experience, and who are going through CDL training (and the CDL trainer is a school and not an employer): does the school have to do a query on the trainees? Or is there an exemption?

Answer: According to guidance issued as part of 49 CFR Part 382, driver training schools meet the definition of an employer because “they own or lease CMVs and assign students to operate them at appropriate points in their training. Similarly, students who actually operate CMVs to complete their course work qualify as drivers.” See question #2 at this link. https://www.fmcsa.dot.gov/regulations/title49/part/382

Question: There is a lot of confusion about individuals that do not have their CLPs will still be added to Clearinghouse if DOT drug test was completed. True or false?

Answer: False - if a CLP or CDL doesn't exist, then the person will NOT be added to the Clearinghouse. It is ONLY for CDL and CLP holders

Question: Another question about CDL trainees: Does a student driver have to have a CLP prior to the query, OR, can a query be done if the student only has a state DL

Answer: If a driver doesn't have a CLP or CDL, a query should not be performed on the driver. Any query performed on a driver without a CLP or CDL will not return any results.


Stay up to date on CDL trucking trends! Be sure to check out the DriverReach blog or follow us on LinkedIn for other relevant articles and head over to our webinars page for an up-to-date list of upcoming events and on-demand recordings.

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