Frequently Asked Questions for SAPs

What are DOT’s training requirements for a SAP?
When did this rule become effective?
I was previously trained under regulations that were in effect prior to August 2001. Must I go through another training?
What must be included in a SAP training?
I heard that DOT was going to permit SAPs to “self-study”. Can I self-study instead?
What if I just tell people that I have been trained? Who’s going to know the difference?
Are there other requirements related to the training?
I have completed a training, but I have not yet taken an exam. Can I provide SAP services?
What’s the difference between Qualification Training and Continuing Education Training?
I took a training several years ago, under the old rules. Should I be looking at Continuing Education Training?
What qualifications or credentials must I have in order to be a SAP?
I am an addictions counselor, and I am licensed by my state. Is that OK for providing SAP services?
I am not sure I want to be a SAP. I think I’d like to do a few assessments just to see what it’s like, and then decide if I want to sign up for a training. Can I do that?
What should I be looking for in a SAP Qualification Training course?
When should I plan to start Continuing Education training?
How will DOT find out if I’m qualified, or if I have met the training requirement?
Does DOT provide trainings for SAPs?
Does DOT maintain a master list of SAPs?
Is there really a market for SAPs?
I am an independent counselor, and I have a private practice. Can I be a SAP?
Will I be able to find SAP business? How will I do it?
Do SAPs really get audited?
Will a SAP training make me a certified or approved SAP?

#1 What are DOT’s training requirements for a SAP?
DOT's regulations require that SAPs must complete a Qualification Training and satisfactorily complete a SAP Exam before they start providing SAP services. [40.281(c)]

#2 When did this rule become effective?
The rule took effect on August 1, 2001. DOT holds all service agents responsible for knowing the rule, and for providing services that are compliant as of that date.

#3 I was previously trained, under regulations that were in effect prior to August 2001. Must I go through another training?
Yes. The rule requires all SAPs to be formally trained under the revised rules, which went into effect on August 1, 2001. SAPs who were previously trained, under the old rules, must be re-trained under the revised rule, and new SAPs must be trained before they can begin providing SAP services.

#4 What must be included in a SAP training?
DOT requires a Qualification Training to provide instruction on the following subjects: [49 CFR Part 40.281(c)]
i) Background, rationale, and coverage of DOT’s drug and alcohol testing program;
ii) 49 CFR Part 40 rules, and the drug and alcohol testing rules of the six operating administrations. (each agency has its own rules);
iii) Key DRUG testing requirements, including collections, laboratory testing, MRO review, and problems in drug testing;
iv) Key ALCOHOL testing requirements, including the testing process, the role of BATs and STTs, and problems in alcohol testing;
v) SAP qualifications, and SAP prohibitions;
vi) The role of the SAP in the return-to-duty process, including the initial employee evaluation, referrals for education and/or treatment, monitoring during treatment/education, the follow-up evaluation, the follow-up testing plan, and setting up an aftercare program;
vii) SAP consultation communication with employers, MROs, treatment providers, and other service agents;
viii) Reporting and recordkeeping requirements;
ix) Issues that SAPs confront in carrying out their duties under the program.

#5 I heard that DOT was going to permit SAPs to “self-study”. Can I self study instead?
“Self-study” is defined in this context as reading and studying the regulations, without a formal structure or instruction. Under this rule, however, self-study is not acceptable to DOT. A SAP must participate in some form of formal SAP training. Classroom training, use of a structured workbook, and internet training would all be acceptable to DOT.

#6 What if I just tell people that I have been trained? Who’s going to know the difference?
The regulations require a SAP to document trainings. [40.281(e)] You should expect to receive a certificate at the end of a training, verifying that you were in attendance for the training. An employer, or a service agent, or a DOT auditor/inspector may request copies of your training documentation, and you are then required, under the rule, to provide that documentation.

#7 Are there other requirements related to the training?
Yes. DOT has added the requirement that SAPs must successfully complete an examination that covers all the elements listed in the response to Question #4, above. (information on SAP Exams).

#8 I have completed a training, but I haven't yet taken an exam. Can I provide SAP services?
The regulation states clearly that a training must be completed. Following successful completion of the training, the SAP must then satisfactorily complete an exam. Until both of these have been completed, in that order, you cannot provide SAP services.

#9 What’s the difference between Qualification Training and Continuing Education Training?
Qualification Training is the initial training that a SAP must have. This training explains the rules and regulations, and the SAP process. The rule does not specify how many hours this training must be. The training must address all required topic areas. (See Question #4, above).

Continuing Education Training is required of SAPs who have completed Qualification Training and who are performing SAP functions. Continuing Education Training is designed to update SAPs on changes and developments in the DOT drug and alcohol testing program. SAPs must complete 12 hours of Continuing Education every 3 years. The rules also state that the continuing education activities must include "documentable assessment tools to assist you in determining whether you have adequately learned the material." Yes, more tests. [40.281(d)]

#10 I took a training several years ago, under the old rules. Should I be looking at Continuing Education Training?
No. Even though you have been trained under the previous rules, you must first complete a Qualification Training under the rules that went into effect on August 1, 2001, and you must satisfactorily complete a SAP examination. The Continuing Education Training requirement doesn't apply until after you have completed a SAP exam.

#11 What qualifications or credentials must I have in order to be a SAP?
SAP qualifications or credentials fall into three categories: 1) Credentials, 2) Basic knowledge, and 3) Training. In order to be a SAP, you must meet the requirements of each category.

Credentials
You must have one of the following credentials:
a) You are a licensed physician [Doctor of Medicine or Osteopathy];
b) You are a licensed or certified social worker;
c) You are a licensed or certified psychologist;
d) You are a licensed or certified employee assistance professional;
e) You are a state-licensed or certified marriage and family therapist; or
f ) You are a drug and alcohol counselor certified by the National Association of Alcoholism and Drug Abuse Counselors Certification Commission (NAADAC); or by the International Certification Reciprocity Consortium/Alcohol and Other Drug Abuse (ICRC); or by the National Board for Certified Counselors, Inc., and Affiliates/Master Addictions Counselor (NBCC).

Basic knowledge
You must be knowledgeable in the following areas:
a) You must be knowledgeable about and have clinical experience in the diagnosis and treatment of alcohol and controlled substances-related disorders.
b) You must be knowledgeable about the SAP function as it relates to employer interests in safety-sensitive duties.
c) You must be knowledgeable about Part 40, and about the DOT agency regulations that apply to the employers for whom you evaluate employees, and about the DOT SAP Guidelines. You must also keep current on any changes to these rules and regulations.

Training
a) You must complete Qualification Training
b) You must actively participate in Continuing Education Training (12 CEUs every 3 years)

#12 I am an addictions counselor, and I am licensed by my state. Is that OK for providing SAP services?
If your only credential is in addictions, you must hold one (or both) of the certifications in Question #11 (Credentials)(e) above. Your addictions credential must be one that allows you to provide services in all states without requiring you to be re-certified or re-credentialed. If your certification restricts you from providing service in any other states, you do not meet DOT's requirement as a SAP. However, you may qualify under one of the other listed credentials.

#13 I am not sure I want to be a SAP. I think I’d like to do a few assessments just to see what it’s like, and then decide if I want to sign up for a training. Can I do that?
No. The SAP process required under these DOT rules is in many ways different from standard chemical use assessments. This SAP process, spelled out in the regulations, is not “business as usual.” (For example, these rules do not permit a SAP to require an employee to sign a release of information. [49 CFR Part 40.355(a)]. Because this process falls under federal laws, you would want to be sure you understand these laws completely before you put yourself, your career, and the employers that you work for, in a position of liability by providing incomplete or non-compliant services.

#14 What should I be looking for in a SAP Qualification Training course?
Here are some questions to ask about a SAP Qualification Training course:
· Does the training include all the points required in the regulations, including at minimum, all the points listed in Question #4 above?
· Does the trainer know the topic? A SAP training requires knowledge in a number of areas: the regulations, assessment and referral, drug and alcohol testing, policies and procedures.
· Will the training go beyond the regulations? Try to find a training that will include case studies, SAP stories, and actual situations and problems that SAPs have encountered. Trainers who are in regular contact with SAPs and employers will be in the best position to speak from experience.
· Will the training explain required reporting format and required information? Will it use case studies? What should NOT be included in a report can be as important as knowing what should be included.
· Will the training give you practical information about setting up a SAP practice? Once you have been trained, how will you market yourself in your community?
· Will the training provide you with resources so that you can get answers to questions on your own? After the training, you want to be able to refer to your manual, or your class notes, or log on to the web, and find your own answers to new questions and new issues as they occur.
· What have you heard from others who have taken this training? Consider the reputation of the trainer, the organization.
· What should NOT be in a training? Since the regulations require a SAP to have basic knowledge related to diagnosis and treatment, a training should not spend time teaching participants how to conduct an assessment. These skills must be well-established by the time you decide to take a SAP training. If you feel you need training in how to do a basic assessment, then you really don’t meet the requirements set by DOT. A SAP's job is to diagnose, and then to design a treatment plan, and refer to a therapeutically appropriate treatment/education program.
· Finally, be wary of trainings that claim to be DOT-approved, or DOT-endorsed. DOT does not approve or endorse trainers or programs. It is possible, however, that DOT might review training programs for accuracy and compliance.

#15 When should I plan to start Continuing Education training?
The clock starts ticking when you have satisfactorily passed an exam following successful completion of a Qualification Training. At that point you will be required to participate in 12 hours of Qualification Training every 3 years.

#16 How will DOT find out if I’m qualified, or if I have met the training requirement?
You must keep records on your trainings, and on the satisfactory completion of exams that follow each training. You must provide that documentation to any service agents that ask for it, including: an EAP who is considering adding you to its SAP network, or a consortium or third-party administrator who is compiling a list of qualified SAPs for its employer clients. An employer who is considering you as a SAP may also ask you to provide this documentation. If you are unable to provide documentation to a service agent, that service agent will probably not ask you to provide SAP services.

A request for proof of credentials and documentation of training could also be made by a DOT auditor, as part of an audit of an employer for whom you provide SAP services. [40.281(e)]

#17 Does DOT provide trainings for SAPs?
No. DOT's role is limited to making the rules.

#18 Does DOT maintain a master list of SAPs?
No. A SAP list is an example of a product or service developed by service agents. There are a few SAP lists in existence, available on the Internet and on paper. The host of a SAP list may or may not charge SAPs a fee to have their names on the list. Some lists are distributed freely, while other lists are sold to employers. Any of these arrangements are acceptable under the law.

The new rule, however, specifically prohibits employers from charging an employee for a list of SAPs. [40.287]

#19 Is there really a market for SAPs?
This rule covers over 12 million employees who work in the transportation industry. 11 million of these employees are truck drivers, who are subject to random testing for drugs at a rate of 50% annually. That means that potentially more than 5 million drug tests are conducted in a year. The trucking industry is currently experiencing a positive rate of more than 1%, which translates to over 50,000 truck drivers, nationwide, annually, who are required to complete a SAP process before they can be considered for return to safety-sensitive function. Remember also that these employees are subject to other DOT-required testing as well, which only increases the need for SAP assessments.

#20 I am an independent counselor, and I have a private practice. Can I be a SAP?
You most certainly can. You can work as a SAP independently. You can also be an affiliate SAP for a large EAP, or for a SAP network, working with employees in your area who require a SAP assessment before they can be considered for return to safety-sensitive duties.

#21Will I be able to find SAP business? How will I do it?
There is definitely a need for SAPs. You may have to think about ways to market yourself to employers and EAPs in your area. This will require some thoughtful planning and initiative, but it’s not difficult. And once you start, you will probably be surprised at how the word gets around.

#22 Do SAPs really get audited?
Yes. When DOT audits an employer, the auditors will certainly review SAP reports. (Without a final SAP report of compliance, the employee cannot be considered to return to safety-sensitive function.) The SAP report must include the SAP’s phone number, and the auditor might decide to inspect the SAP’s records. The auditor might talk to the SAP by phone. The auditor might also go directly to the SAP’s office, ask to see credentials, ask to see training documentation, and may ask to review some of the SAP’s DOT client files. The auditor requires no authorization from any of those clients. The SAP would be expected to make the files immediately available.

#23 Will a SAP training make me a certified or approved SAP?
The first sentence in Section V, SAP Guidelines is this: "DOT does not certify, license, or approve individual SAPs." Following a training, the most that you can say is that you meet the qualifications (See Question #11 above), and that you have been trained. You cannot say you are a "certified SAP", and you cannot call yourself an "approved SAP." DOT says that those who do are making false claims.