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Return-to-Duty Program Blueprint

A repeatable workflow for coordinating MRO review, SAP engagement, observed testing, and Clearinghouse milestones after a violation.

A repeatable workflow for coordinating MRO review, SAP engagement, observed testing, and Clearinghouse milestones after a violation.

Return-to-Duty cases stall when employers lack structured workflows—missed follow-up tests trigger new violations that restart the entire process, delays in SAP coordination extend driver removal periods, and incomplete Clearinghouse reporting creates audit failures. This 18-page blueprint mirrors the DSC Return-to-Duty program (used to manage 200+ RTD cases with 98% completion rate and zero missed Clearinghouse deadlines) so safety managers can keep drivers on track without missing a single milestone.

The blueprint provides step-by-step procedures, timeline guardrails, communication templates, and documentation checklists that transform the complex RTD process into a repeatable, organized workflow.

The blueprint shortens RTD cycle time (target: 45-60 days from violation to return), protects legal exposure from improper early returns or incomplete processes, and ensures every test is directly observed per Part 40 requirements. Includes decision flowcharts for accommodating drivers during treatment, managing workers' compensation interactions, and handling drivers who fail follow-up tests.

  • Complete timeline from violation discovery through follow-up test completion: Day-by-day milestones covering MRO verification, driver removal, Clearinghouse initial reporting, SAP referral, evaluation completion, treatment verification, RTD test scheduling, negative result confirmation, return authorization, and 12-60 month follow-up plan administration
  • Roles and responsibilities matrix: Clear accountability assignments for DERs (result receipt, removal decisions, Clearinghouse reporting), SAPs (evaluation, treatment recommendations, follow-up plans), collectors (directly observed collections), MROs (result verification, driver interviews), and fleet leadership (employment decisions, accommodation considerations, cost management)
  • Sample communications for drivers, operations, and insurance stakeholders: Template language for removal notifications, SAP referral letters, RTD eligibility confirmations, follow-up test scheduling, and status updates that preserve driver dignity while maintaining compliance rigor
  • Clearinghouse reporting checkpoints: Mandatory milestones with submission deadlines—initial violation report (within 2 business days), RTD test completion (within 2 business days), follow-up plan initiation, and each follow-up test completion
  • Documentation requirements and audit defense: Evidence retention protocols covering MRO verification letters, SAP reports, directly observed collection confirmations, negative RTD results, follow-up schedules, and completion certificates
  • Cost management strategies: SAP evaluation expenses ($400-$800), treatment costs (variable), testing fees ($95-$225 per directly observed test), and employer payment obligations versus driver responsibility

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