DOT Drug Testing Consortium vs. TPA: Which Does Your Fleet Need? (2026)
Quick Answer
Yes. Every driver who operates a commercial motor vehicle (CMV) requiring a CDL in interstate commerce must be included in a DOT random drug and alcohol testing pool under 49 CFR Part 382. This applies to part-time drivers, seasonal drivers, and drivers classified as independent contractors if the carrier has actual control or right to control their driving duties.
Every FMCSA-regulated carrier must have a DOT drug and alcohol testing program under 49 CFR Part 382 — but the question of whether you need a consortium, a TPA, or a C/TPA confuses thousands of carriers every year. The answer depends almost entirely on one thing: whether you have employees. Owner-operators with no CDL employees must join a consortium. Carriers with employees have more options — but employer responsibility never transfers to the service agent. This guide explains exactly how each program type works, what your C/TPA actually manages, and what you remain responsible for regardless.
50%
Random rate — controlled substances
10%
Random rate — alcohol
Mar 15
MIS annual report due date
5 years
Positive test record retention
In This Guide
Consortium vs. TPA: The Core Difference
The confusion between a consortium and a TPA is understandable — the terms are often used interchangeably by vendors who want your business, but they describe meaningfully different program structures. Understanding the difference is not an academic exercise: getting it wrong can result in a citation for having no valid random testing program, one of the most serious violations in an FMCSA compliance review.
A Third Party Administrator (TPA) is a service agent that manages the administrative functions of a DOT drug and alcohol testing program on behalf of an employer. The TPA handles the logistics: scheduling collections, coordinating with collection sites, managing results from the Medical Review Officer (MRO), and maintaining records. A TPA may manage a program for a single employer with 50 drivers, or for 5 separate employers — but in a TPA-only arrangement, each employer's drivers remain in a separate pool.
A Consortium is a group of employers who combine their drivers into a single shared random testing pool. When the random selection is made, names are drawn from the combined pool — not from each employer's individual driver list. This pooling is the defining characteristic of a consortium. A carrier with two drivers has an effective random selection rate that is accurate because selections are drawn across hundreds of drivers in the pool, not just from a two-person list where statistical randomness breaks down.
A C/TPA (Consortium/Third Party Administrator) does both: it operates a consortium pool and provides TPA administrative services. Most DOT drug testing service providers that market to small carriers and owner-operators are C/TPAs — they pool drivers across many clients into a combined random selection pool while also managing all the administrative functions of the testing program.
Consortium vs. TPA vs. C/TPA: Side-by-Side
| Feature | Consortium | TPA | C/TPA |
|---|---|---|---|
| Pools drivers across employers? | Yes | No | Yes |
| Manages admin functions? | Not always | Yes | Yes |
| Valid for owner-operators? | Yes | No | Yes |
| Conducts random selections? | Yes | Yes (per-employer) | Yes (pooled) |
| Typical client size | 1–5 drivers | 10+ drivers | Any size |
For most small carriers, a C/TPA is the right answer — it gives you both the pooled random testing program and the administrative support to manage the rest of your program. The question of whether to manage your program in-house really only becomes practical for carriers with 200+ drivers, where internal HR and safety departments have the bandwidth to manage the program without external help.
Why Owner-Operators Must Join a Consortium
The requirement that owner-operators join a consortium is one of the most frequently cited violations in FMCSA compliance reviews, and it is almost always cited because the owner-operator either did not know the rule existed or believed their C/TPA membership from a prior employer was still active. The rule is clear and the enforcement is real.
Under 49 CFR § 382.305, every employer must conduct random drug and alcohol testing at the required annual rates. The term "random" has a specific regulatory meaning: selections must be made by a method that gives each covered driver an equal chance of being tested each time selections are made, and selections must be scientifically valid. An owner-operator cannot make a scientifically valid random selection from a pool containing only themselves.
The Owner-Operator Self-Testing Problem
Even if an owner-operator were to implement a schedule — say, testing every third month — this is not a random program under the regulation. A predetermined schedule is predictable, not random. FMCSA requires that selections be made by an unbiased, scientifically valid method, which by definition requires a pool of more than one driver.
The only compliant solution: join a DOT drug testing consortium.
When an owner-operator joins a consortium, their name goes into a pool with other drivers from other carriers. The C/TPA draws names from this combined pool at the required rates. If selected, the owner-operator receives notification and must report to a collection site within the required timeframe. Because the selection comes from the full pool, the owner-operator's chances of being selected in any given period are proportional to their representation in the pool — exactly what the regulation requires.
Owner-operators who lease their trucks to a motor carrier are a special case. When an owner-operator is leased to a carrier, the carrier (not the owner-operator) is responsible for including that driver in their DOT drug testing program. The carrier must add the leased owner-operator to their pool for the duration of the lease. If the owner-operator later ends the lease and operates under their own authority, they must immediately join a consortium independently — there is no grace period.
Compliant Owner-Operator Setup
- Member of a DOT consortium with pooled random testing
- Pre-employment test on file before first DOT run
- Annual MIS report filed by March 15
- Clearinghouse query conducted annually
- Testing records retained per Part 382 schedule
Common Owner-Operator Violations
- No random testing program at all
- Attempting to self-administer random testing
- Consortium membership lapsed without notice
- No pre-employment test on file
- MIS annual report never filed
Random Testing Rates: What FMCSA Requires
FMCSA sets the minimum annual random testing rates for controlled substances and alcohol under 49 CFR § 382.305. These rates are not fixed permanently — FMCSA reviews industry-wide positive test data each year and publishes updated rates in the Federal Register. The 2024 rates, which most carriers are currently operating under, are:
50%
Controlled Substances
Minimum annual random testing rate for drugs (marijuana, cocaine, opioids, amphetamines, PCP)
10%
Alcohol
Minimum annual random testing rate for alcohol; test must be conducted just before, during, or just after safety-sensitive duty
These rates are minimum rates — a carrier can always test more frequently, but cannot test less than the published minimum. The rate is applied to the average number of driver positions in the pool during the year, not to the number of individual drivers who worked at some point during the year.
For example, if a carrier has an average of 20 drivers in their pool throughout the year, they must conduct at minimum 10 random drug tests and 2 random alcohol tests during that calendar year. These tests must be spread throughout the year — a carrier cannot front-load all their random tests in January and claim compliance for the year.
How Rates Can Change
Under 49 CFR § 382.305(b), if the controlled substances positive rate for the industry falls below 1.0% for two consecutive years, FMCSA may reduce the minimum rate to 25%. Conversely, if the rate rises above 1.0%, the minimum returns to 50%. As of 2024, the industry-wide positive test rate remains above 1.0% — driven largely by marijuana positives — so the 50% rate is in effect. Your C/TPA should notify you of any rate changes, but you are responsible for compliance regardless of whether you receive notice.
One of the most common testing rate violations in small carriers is running at the old 25% rate without realizing FMCSA returned to 50%. Another is failing to count all CDL drivers in the pool — for example, not including recently hired drivers in the pool calculation, resulting in an understated driver count and a lower-than-required number of tests.
How Random Selections Must Be Conducted
The term "random" is defined with regulatory precision in 49 CFR Part 382. Not every testing schedule that feels random to the employer is compliant. The regulations require that:
Each driver must have an equal chance of selection each time
The pool must operate so that any driver can be selected in any testing period, regardless of whether they were recently tested. Past selection does not exempt a driver from future selection — a driver can theoretically be selected multiple times in a single year.
Selections must be made by a scientifically valid method
FMCSA accepts computer-based random number generators as the standard method. Manual draws — pulling names from a hat — are not prohibited, but must be documented rigorously and are generally not recommended for small carriers because documentation of genuine randomness is difficult to demonstrate to an auditor.
Tests must be spread throughout the year
Selections must be spread reasonably throughout the calendar year — a carrier cannot conduct all required random tests in a single month and claim the annual rate is met. FMCSA expects at least quarterly selection periods, though more frequent selections are permissible.
Testing must occur while the driver is on duty performing safety-sensitive functions
Random alcohol tests must be conducted just before, during, or just after the driver is performing safety-sensitive functions. Drug tests may be conducted at any time, but the driver must report for testing immediately upon notification. A driver who is off-duty when notified must be tested when they return to duty before performing safety-sensitive functions.
Post-Accident Testing: A Separate Requirement
Post-accident testing is often confused with random testing — they are entirely separate requirements. Under 49 CFR § 382.303, drug and alcohol testing is required after certain qualifying accidents involving a commercial motor vehicle. The triggers are:
| Accident Circumstance | Drug Test Required | Alcohol Test Required |
|---|---|---|
| Fatal accident (human fatality) | Yes — always | Yes — always |
| Bodily injury requiring immediate medical treatment away from scene | Yes | If citation issued |
| Vehicle disabled requiring towing | Yes | If citation issued |
Alcohol testing must be completed within 2 hours of the accident; if it cannot be completed within 8 hours, the employer must document why. Drug testing must be completed within 32 hours; if it cannot be completed within 32 hours, the employer must document why testing was not possible. If testing is not completed within these timeframes, the failure must be documented — but the employer may still face questions about why testing was not completed timely.
Post-accident tests must be ordered by the employer — not by law enforcement. A roadside drug or alcohol test conducted by police or a state trooper at the accident scene does not satisfy the DOT post-accident testing requirement. The DOT test must go through a FMCSA-approved collection site and a certified MRO. Employers should brief their drivers on this distinction before an accident occurs — a driver who submits to a law enforcement test at the scene and believes they are "done" will not report for the DOT test within the required window.
What Your C/TPA Actually Manages
When you contract with a C/TPA, you are hiring a service agent to handle the operational complexity of your DOT testing program. Understanding exactly what the C/TPA handles — and what they cannot handle — is essential for both compliance and for auditing your service provider's performance.
A well-run C/TPA will manage the following on your behalf:
Random Pool Management
Maintains your driver roster in the consortium pool, handles additions and removals when drivers are hired or terminated, and ensures your pool is accurate at the time of each random selection period.
Random Selections and Driver Notification
Conducts computer-generated random selections from the pool at the required rates, notifies your selected drivers, and tracks that notification was received. Properly documents the selection method to demonstrate scientific validity to FMCSA auditors.
Collection Site Coordination
Maintains a network of DOT-approved collection sites (clinics, urgent care centers, testing facilities) near your operating areas. Provides drivers with collection site locations, authorization forms, and chain-of-custody documentation.
MRO Result Management
Receives test results from the Medical Review Officer (MRO), transmits results to the employer, and maintains result records in accordance with Part 382 retention requirements. Tracks split specimen requests if a driver contests a positive result.
MIS Annual Report Data Collection
Compiles your annual testing data (number of tests conducted, number of positives, number of refusals) for the MIS Annual Report due March 15. Most C/TPAs will prepare the report data — but the employer must review, sign, and submit.
Record Retention and Audit Support
Maintains testing records in secure, retrievable format. Provides documentation packets during FMCSA audits and compliance reviews. Can respond directly to FMCSA data requests on the employer's behalf if authorized.
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Employer Responsibility: What C/TPA Cannot Do For You
This section is the most important in this guide — and the one most carriers get wrong. Using a C/TPA does not transfer employer liability. FMCSA is explicit on this point in 49 CFR Part 40, Subpart Q: "The employer remains responsible for compliance with all applicable DOT agency regulations, including this part." If your C/TPA fails, you pay the penalty.
Beyond the general responsibility principle, there are specific decisions and actions that belong to the employer by regulation and cannot be delegated to a C/TPA:
Actions That Cannot Be Delegated to a C/TPA
Return-to-duty decisions: After a positive test, the employer decides whether and when to return a driver to safety-sensitive duty, following the SAP process. The C/TPA cannot make this decision.
Immediate removal: When a positive result is received, the employer must immediately remove the driver from safety-sensitive duty. The C/TPA can notify you, but the removal action is yours.
Clearinghouse annual queries: Employers must conduct annual general queries for all safety-sensitive employees. C/TPAs can assist, but the employer must ensure completion and pay for each query.
MIS report submission: The C/TPA prepares the data; the employer certifies and submits. FMCSA holds the employer responsible for late or missing MIS reports, not the C/TPA.
Driver notification of results: The employer — not the C/TPA — must inform drivers of positive test results through the MRO in accordance with the regulatory process.
Ensuring test completion: If a selected driver fails to report for testing, the employer must treat the failure-to-appear as a refusal to test. The C/TPA can flag it, but the employer's action is required.
The practical implication: you cannot set up a C/TPA program and then ignore it for 12 months. You need a designated person at your company — whether that is you, your safety director, or an HR manager — who actively monitors the program, responds to positive result notifications, and audits the C/TPA's performance against your compliance obligations at least quarterly.
The MIS Annual Report: Due March 15 Every Year
The Management Information System (MIS) Annual Report is one of the least understood obligations in DOT drug testing compliance — and one of the most reliably cited violations when it is missing. Every FMCSA-regulated employer, regardless of fleet size, must report their prior year's drug and alcohol testing data to FMCSA by March 15 of each year.
The report covers the previous calendar year (January 1 – December 31) and must include:
Drug Testing Data Required
- Number of driver positions subject to testing
- Random tests conducted and rate achieved
- Pre-employment tests conducted and positives
- Post-accident tests conducted and positives
- Reasonable suspicion tests conducted
- Return-to-duty and follow-up tests
- Refusals to test (drugs)
Alcohol Testing Data Required
- Number of driver positions subject to testing
- Random tests conducted and rate achieved
- Pre-employment alcohol tests (if conducted)
- Post-accident tests and violations (≥0.04)
- Reasonable suspicion tests
- Return-to-duty and follow-up tests
- Refusals to test (alcohol)
Electronic filing requirement: Carriers who had 50 or more drivers performing safety-sensitive functions at any point during the reporting year must file electronically through the FMCSA Drug & Alcohol Clearinghouse portal. Smaller carriers may mail paper reports — but electronic filing is available to all carriers and recommended for the built-in confirmation it provides.
MIS Annual Report Timeline
Prior year data collection begins. Start compiling test counts with your C/TPA.
Request MIS data summary from your C/TPA. Verify test counts match your internal records.
Complete and review MIS report. Correct any discrepancies with your C/TPA before submission.
MIS Annual Report due. Submit electronically (50+ drivers) or by mail (under 50 drivers).
Clearinghouse Obligations Employers Cannot Delegate
The FMCSA Drug & Alcohol Clearinghouse, established under 49 CFR Part 382, Subpart G, is a secure online database that contains real-time information about CDL driver drug and alcohol program violations. Since its launch in January 2020, the Clearinghouse has fundamentally changed how employer obligations work — and it has created new compliance requirements that exist entirely outside of what a C/TPA traditionally manages.
There are three Clearinghouse obligations that every FMCSA-regulated employer must meet, and none of them can be fully delegated to a C/TPA:
Pre-Employment Queries
Before a CDL driver first performs safety-sensitive duties for your company, you must conduct a full query of the Clearinghouse. This query checks whether the driver has any unresolved drug or alcohol violations. A driver with a violation on record cannot be permitted to perform safety-sensitive duties until they complete the return-to-duty process with a DOT-qualified Substance Abuse Professional (SAP).
C/TPA role: Can submit the query if granted employer-authorized limited query access. Employer must pay for each query and review results.
Annual General Queries
Every year, you must query the Clearinghouse for every CDL driver currently performing safety-sensitive functions. This is not a one-time event — it happens every calendar year for every active driver. The query reveals any new violations that may have been reported by a prior employer or from off-duty incidents. If a violation is found, the employer must follow the return-to-duty process before the driver may continue performing safety-sensitive duties.
C/TPA role: Can assist with batch queries if authorized. But the employer is responsible for ensuring every active driver is queried each calendar year — the C/TPA's failure is not a defense.
Reporting Violations to the Clearinghouse
When a driver at your company has a drug or alcohol program violation — a positive test, a refusal to test, a verified positive reported by the MRO — the employer must report the violation to the Clearinghouse within two business days of receiving the result. The MRO will also report directly for positive tests, but the employer must report refusals and other non-MRO violations. Failure to report is itself a citable violation.
C/TPA role: Can assist with reporting for violations they are notified of. Employer must ensure all violations are reported, including refusals to test that the C/TPA may not be aware of.
Record retention for testing records under 49 CFR Part 382:
| Record Type | Retention Period |
|---|---|
| Positive drug/alcohol test results; refusals to test | 5 years |
| SAP evaluation and follow-up testing records | 5 years |
| Annual MIS reports | 5 years |
| Employee education and supervisor training records | 2 years |
| Negative and cancelled test results | 1 year |
| Random testing pool documentation | 1 year |
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How to Choose and Audit a C/TPA
Not all C/TPAs are created equal. The market includes large national companies, regional firms, and individual consultants — all offering to manage your DOT drug testing program. Choosing the wrong one, or failing to audit your existing one, is one of the most common paths to a compliance violation. Here is a systematic approach to evaluating any C/TPA before you sign a contract and auditing your current one at least annually.
What to Ask Before Signing With a C/TPA
Are you listed as a service agent on FMCSA's website?
FMCSA maintains a public list of C/TPAs. While not being listed is not disqualifying, unlisted providers warrant additional scrutiny. Ask for their DOT service agent registration documentation.
How large is your consortium pool?
A larger pool provides more statistically valid random selections. A pool of 10 drivers is not meaningfully random. Ask for the approximate pool size — a reputable C/TPA serving many small carriers should have thousands of drivers in the pool.
What collection sites are available in my operating region?
If your drivers operate across multiple states, confirm the C/TPA has a network of DOT-approved collection sites accessible in those areas. A selected driver who cannot reach a collection site within the required timeframe creates a program failure — not a driver failure.
How quickly are positive results communicated to the employer?
When an MRO verifies a positive result, you must act immediately to remove the driver from safety-sensitive duty. Ask what the C/TPA's process is for same-day notification of positive results — this is a compliance-critical timeline.
Do you provide MIS Annual Report preparation and documentation?
The MIS Annual Report requires accurate annual testing data. Ask whether the C/TPA provides a report summary with raw counts, and whether they will provide documentation if FMCSA questions the data during an audit.
Can you assist with Clearinghouse queries?
Ask whether the C/TPA can be designated as your Clearinghouse limited query agent and whether they will prompt you when annual queries are due for each driver. Many C/TPAs now offer Clearinghouse assistance as part of their program — but it requires an employer-initiated authorization in the Clearinghouse portal.
Annual C/TPA Audit: What to Verify
Because the employer remains responsible for all C/TPA errors, you should conduct an annual performance audit of your C/TPA — ideally at the same time you compile MIS Annual Report data. The audit does not need to be complicated; it is primarily a reconciliation of records.
Annual C/TPA Performance Audit Checklist
Random testing rate achieved
Confirm the number of random drug and alcohol tests conducted matches or exceeds the required rates (50% / 10%) applied to your average driver count for the year.
Driver roster accuracy
Compare your C/TPA's driver roster against your internal HR records. Every driver who performed safety-sensitive duties should be in the pool; terminated drivers should have been removed promptly.
Pre-employment test documentation
For every driver hired during the year, confirm a pre-employment drug test was completed with a negative result before first safety-sensitive duty. Missing pre-employment tests are a high-severity citation.
Post-accident test documentation
Review any accidents during the year. Confirm that post-accident testing was completed within required timeframes (8 hours for alcohol, 32 hours for drugs) for qualifying accidents under 49 CFR § 382.303.
Refusal-to-test handling
Any driver who failed to appear for a required random test should have been documented as a refusal and reported to the Clearinghouse. Confirm these were handled correctly.
Supervisor training documentation
Confirm that all supervisors authorized to make reasonable suspicion determinations completed the required 60-minute drug awareness and 60-minute alcohol awareness training. These training records must be retained for 2 years.
When to Consider Switching C/TPAs
Switching C/TPAs is not disruptive if done correctly — you simply notify your current C/TPA, request all your records, and enroll with the new provider. Reasons to consider switching include:
- - Random selections are consistently clustered in the same months (suggests a non-random process)
- - Positive results are not communicated same-day
- - Your driver roster does not match HR records when reconciled
- - MIS Annual Report data cannot be provided in a timely manner
- - The C/TPA cannot provide documentation that FMCSA is requesting
How FileFlo Tracks Your Drug Testing Records
The biggest gap in most small carrier drug testing programs is not the testing itself — it is the documentation. Carriers rely on their C/TPA to store records, but C/TPAs may not retain records for the full retention period required, may not have records accessible in a format FMCSA auditors accept, and typically do not track obligations like Clearinghouse annual query deadlines that exist outside the testing workflow.
FileFlo organizes your drug testing compliance documentation in a single, audit-ready system designed for the realities of FMCSA compliance reviews:
Deadline Tracking
Automated reminders for MIS Annual Report (March 15), annual Clearinghouse query windows, and program review dates — so compliance obligations never fall through the cracks during busy seasons.
Document Storage
Upload and organize test result records, MIS report submissions, SAP evaluation documents, supervisor training certificates, and Clearinghouse query confirmations — all indexed by driver and date.
Driver-Level View
See each driver's complete testing history — pre-employment, random, post-accident — alongside their DQF documents, medical card status, and training records in a single profile.
Audit Packet Export
When FMCSA requests records during a compliance review, generate a complete, organized export of your drug testing documentation in minutes — not hours of searching through filing cabinets or emailing your C/TPA.
DOT drug testing is a program that requires ongoing management, not just a one-time setup. A C/TPA handles the testing logistics. FileFlo handles the compliance oversight — deadlines, records, and audit readiness — so your program is complete from every angle FMCSA will check.
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Frequently Asked Questions
Yes. Every driver who operates a commercial motor vehicle (CMV) requiring a CDL in interstate commerce must be included in a DOT random drug and alcohol testing pool under 49 CFR Part 382. This applies to part-time drivers, seasonal drivers, and drivers classified as independent contractors if the carrier has actual control or right to control their driving duties. Drivers who hold a CDL but are not currently performing safety-sensitive functions may be temporarily removed from the pool, but this requires careful documentation.
No. An owner-operator who operates as a sole proprietor with no CDL employees cannot administer their own random testing program. The regulations require random selections to be made by an unbiased third party, and an owner-operator cannot randomly select themselves. The only compliant option for a solo owner-operator is to join a DOT drug testing consortium where selections are made from a pooled group of drivers. This is one of the most commonly cited violations in FMCSA compliance reviews.
A TPA (Third Party Administrator) is a service agent that manages the DOT drug and alcohol testing program on behalf of an employer. A C/TPA (Consortium/Third Party Administrator) is a specific type of TPA that also operates a consortium — a pooled random testing program where multiple employers' drivers are combined into a single pool for random selections. All C/TPAs are TPAs, but not all TPAs operate consortiums. For carriers with multiple drivers, either can work. For owner-operators with no employees, only a C/TPA that runs a consortium pool meets the random testing requirement.
For 2024, FMCSA set the minimum annual random testing rate at 50% for controlled substances and 10% for alcohol. These rates are set annually by FMCSA based on industry positive test rate data. If the industry positive test rate for controlled substances falls below 1.0% for two consecutive years, FMCSA may reduce the rate to 25%; if it rises above 1.0%, the agency can return the rate to 50%. Carriers must test at or above the published annual minimum rates — testing more frequently than the minimum is always permissible.
Yes. Under 49 CFR Part 40 and Part 382, the employer is ultimately responsible for compliance with all DOT drug and alcohol testing requirements. Using a C/TPA or TPA as a service agent does not transfer liability to the C/TPA. If your C/TPA fails to conduct a required random test, fails to report a positive result correctly, or misses the MIS annual report deadline, the citation falls on you as the employer — not the service agent. This is why carrier compliance officers should audit their C/TPA's performance annually, not just assume the program is running correctly.
The Management Information System (MIS) Annual Report for DOT drug and alcohol testing data is due by March 15 each year, covering data from the prior calendar year. All FMCSA-regulated employers — including those with as few as one CDL driver — must complete the MIS report. Employers with 50 or more drivers in safety-sensitive positions during the reporting year must submit the report electronically through the FMCSA Drug & Alcohol Clearinghouse portal. Smaller carriers may report by mail. Your C/TPA can assist with data collection, but the employer is responsible for accuracy and timely submission.
Record retention under 49 CFR Part 382 varies by record type: positive drug or alcohol test results and refusals to test must be kept for 5 years; negative and cancelled test results must be kept for 1 year; annual MIS reports must be kept for 5 years; records documenting employee education and supervisor training must be kept for 2 years; SAP evaluation and follow-up testing records must be kept for 5 years. All records must be kept confidential and must be provided to FMCSA or DOT upon request during an audit or compliance review.
The FMCSA Drug & Alcohol Clearinghouse (launched January 2020) requires employers — not C/TPAs — to conduct annual queries on all drivers performing safety-sensitive functions. Your C/TPA can be designated as your Clearinghouse assistant and can submit queries on your behalf if you grant them limited query access, but the employer must ensure the annual query is completed. Additionally, employers must make pre-employment queries before a new driver first performs safety-sensitive duties, and must report drug/alcohol program violations to the Clearinghouse. FMCSA conducts Clearinghouse audits, and failure to perform required queries is a citable violation.
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