Clearinghouse Compliance
FMCSA Clearinghouse compliance for owner-operators and small fleets
The FMCSA Drug & Alcohol Clearinghouse puts duties on employers that are easy to miss: a query when you hire, a query every year for every CDL driver, and, for owner-operators, a consortium/third-party administrator designated to report for you. Software tracks which queries your operation owes and when each driver's twelve-month clock runs out; a person prepares them, and the steps inside the Clearinghouse are done by you, or by the C/TPA you designate, from your own account.
What we do
Registration guidance
We walk you through Clearinghouse registration and get your account set up correctly.
Query scheduling
Pre-employment queries when you add a driver, and annual queries for every current CDL driver, tracked and prepared so none are missed.
C/TPA coordination
Owner-operators must designate a C/TPA. We tell you which consortium to name, walk you through the designation in your own account and coordinate with the consortium so the pieces connect.
Recordkeeping
Query results and consents are filed where you can find them.
Who it's for: Every carrier employing CDL drivers, and especially owner-operators, who carry employer duties for themselves.
The two queries, in short
Before a driver first performs safety-sensitive work for you, 382.701(a)(1) requires a full query, with the driver's consent given inside the Clearinghouse. For the annual check, 382.701(b)(2) allows the limited query instead. How the two differ, what each result means and what consent each one needs are set out in limited vs full Clearinghouse queries.
The 24-hour rule
If a limited query comes back indicating that information exists, 49 CFR 382.701(b)(3) gives you 24 hours to run a full query. Miss that window and the driver must be pulled from safety-sensitive functions until a full query confirms no prohibition. For a one-truck operation, that means you stop driving, which is why running the annual query on a Friday afternoon is a bad habit.
Designating a C/TPA as an owner-operator
If you run under your own authority, you are simultaneously the employer and the driver, and FMCSA does not let you sit on both sides of your own query. You must designate a consortium/third-party administrator to perform Clearinghouse reporting duties on your behalf, and that designation has to be made in your Clearinghouse account. The steps, in the order the Clearinghouse asks for them, are in Clearinghouse registration for owner-operators.
This is the single most common Clearinghouse gap in one-truck operations: the carrier registers, never designates a C/TPA, and assumes registration alone satisfies the requirement. It does not. The consortium that runs your random pool is usually the C/TPA you name, which is why we set the two up together in the DOT drug and alcohol program.
What prohibited status now costs, the second Clearinghouse rule
As of November 18, 2024, the second Clearinghouse final rule requires state driver licensing agencies to remove commercial driving privileges from any driver in prohibited status. States must also query the Clearinghouse before issuing, renewing, upgrading or transferring a commercial credential.
The practical effect is that a prohibition is no longer only an employment problem. It reaches the license itself. The route back runs through the return-to-duty process in 49 CFR Part 40, Subpart O: an evaluation by a substance abuse professional, completion of whatever they prescribe, and a negative return-to-duty test before the status changes and the state can reinstate.
On the timelines you will see quoted
Plenty of articles cite a specific number of days between prohibited status and downgrade. FMCSA’s own Clearinghouse guidance does not publish a single national figure, and state processes differ. Treat any specific day count you read (including from a compliance vendor) as something to verify with your state licensing agency rather than to plan around.
What actually has to be on a calendar
Clearinghouse obligations are recurring, and the annual one is the one that slips. It is not tied to a convenient date like January 1. It runs on each driver’s own twelve-month cycle, which for a growing fleet means several unrelated anniversaries.
Your Clearinghouse obligations at a glance
| Obligation | Query type | Regulation | Frequency |
|---|---|---|---|
| Before a driver first drives for you | Full: needs specific consent | § 382.701(a)(1) | Once, per driver, at hire |
| Ongoing check on employed drivers | Limited is permitted | § 382.701(b)(1) and (2) | At least once every 12 months |
| Limited query returned a hit | Full | § 382.701(b)(3) | Within 24 hours |
| Designate a C/TPA (owner-operators) | Not a query | Part 382, Subpart G | Once, kept current |
| Report violations you learn of | Not a query | § 382.705 | By the third business day |
What Clearinghouse setup costs
TenFour membership, first truck
$99/month
Billed annually ($1,188/yr) · $119 month to month · +$59/month per additional truck
Billed annually; each additional truck +$59/month, every driver included. Registration help in your own account, driver consents, the pre-employment and annual queries and the records that prove them are included. You buy queries ($1.25 each) directly from FMCSA in your own Clearinghouse account.
Clearinghouse setup, standalone
$249 one-time
Registration help in your own account, consent forms, the first query and an annual query calendar. You pay query fees directly to FMCSA. For carriers not on a plan. Credited to a plan started within 60 days.
Every price for 1 to 6 trucks is published, no quote form, no sales call. See full pricing. Running 7 or more? Contact us for custom pricing.
What happens if you skip it
Clearinghouse violations are unusually easy for an investigator to prove, because the query record either exists in a federal database or it does not. There is no filing cabinet to search and no benefit of the doubt.
- A missing pre-employment full query is a documented federal violation the moment an investigator opens your account.
- A missed annual query is equally visible, and it repeats for every driver and every year you missed.
- Using a driver in prohibited status is among the violations that fail a new entrant safety audit on a single occurrence.
- Since November 2024, a driver left in prohibited status faces losing their CDL entirely, which for an owner-operator ends the business, not just the load.
Sources
- 49 CFR 382.701: Clearinghouse query requirements
- FMCSA Clearinghouse: CDL downgrades
- 49 CFR Part 40, Subpart O: Return-to-duty process
- FMCSA Drug & Alcohol Clearinghouse
Last reviewed September 26, 2026. TenFour is a compliance service, not a law firm, and is not affiliated with FMCSA or any government agency. This page explains federal requirements in plain English, verify specifics for your operation against the sources above.
Common questions
How often do I need to run Clearinghouse queries?
A full query before a CDL driver first performs safety-sensitive work for you, then at least one query per year for every CDL driver you employ. The annual one may be a limited query. Both requirements are in 49 CFR 382.701.
What is the difference between a full and a limited query?
A full query returns the actual violation information and requires the driver’s specific electronic consent in the Clearinghouse. A limited query only reports whether information exists, without releasing it, and a driver can consent to limited queries for multiple years at once. Pre-employment must be full; the annual check may be limited.
What happens if a limited query comes back with a hit?
You have 24 hours to run a full query under 382.701(b)(3). If you do not, the driver must be removed from safety-sensitive functions until a full query confirms there is no prohibition.
Do owner-operators need to register for the Clearinghouse?
Yes. Under your own authority you are the employer as well as the driver, and FMCSA requires you to designate a consortium/third-party administrator to handle Clearinghouse reporting duties on your behalf. Registering without designating a C/TPA is the most common gap we see.
What is a C/TPA?
A consortium/third-party administrator: a service agent that runs drug and alcohol testing programs for employers, including the random pool, and can be designated in your Clearinghouse account to report for you. An owner-operator must designate one, because the same person cannot be both the employer and the driver being reported on. We tell you which consortium to name and walk you through the designation in your own account.
What does prohibited status do to a CDL?
Since November 18, 2024, state driver licensing agencies must remove commercial driving privileges from drivers in prohibited status, and must query the Clearinghouse before issuing, renewing, upgrading or transferring a commercial credential. Privileges are reinstated only after the return-to-duty process under 49 CFR Part 40, Subpart O.
How long are query records kept?
Keep query results and consents with your drug and alcohol program records. Auditors ask to see proof the required queries happened, so retention is about being able to produce evidence years later, not just running the query at the time.
Does TenFour log into the Clearinghouse for me?
No. You hold your own Clearinghouse login, and we never ask for it, hold it or use it. We prepare everything and track what is due, and the steps that must happen inside the Clearinghouse are done by you or by a C/TPA you have designated in your account. We will never act as you in a federal system.
What does this cost with TenFour?
Clearinghouse registration help, driver consents, the queries the rules require and the records that prove them are part of the membership: $99/month for the first truck on the annual plan, $59/month for each additional truck, every driver included. You buy the $1.25 queries directly from FMCSA in your own account. The C/TPA side is handled as part of the drug and alcohol program: we tell you which consortium to join, complete the enrollment and walk you through naming it as your C/TPA in your own account, and you pay the consortium's own fee directly ($99 a year for the whole account with the consortium we refer you to). Fewer vendors to chase, fewer renewal dates, fewer things to remember.
Handled, for one published price per truck.
Part of the TenFour membership: $99/month for the first truck on the annual plan, +$59/month for each additional truck, every driver included. Built for carriers with 1 to 6 trucks; fleets of 7 or more are priced by conversation.
$99/month is the annual plan for one truck, billed $1,188 up front, about two months free against $119 month to month. Each additional truck is $59/month ($69 month to month), every driver included, up to six trucks. Cancel any month; remaining full months refunded.