Every DOT drug test is documented on a Federal Drug Testing Custody and Control Form, usually called the CCF. It is the multi-part form, or electronic record, that follows a urine specimen from the collection site to the laboratory and the Medical Review Officer (MRO). In 2026, a revised version of the form took effect. The changes are modest, but employers, collectors and drivers may notice them, and there is a deadline for retiring old forms.
Key dates for the 2026 CCF
According to ODAPC's notice on the revised CCF and SAMHSA's guidance for using the 2026 CCF:
- HHS announced OMB approval of the 2026 CCF in May 2026, and the approval took effect April 27, 2026.
- The OMB approval runs through April 30, 2029.
- The 2026 CCF can be used in paper or electronic form.
- The 2023 CCF can continue to be used until May 31, 2027 without a memorandum for the record.
- Starting May 31, 2027, a collection on an old CCF requires a memorandum for the record, under 49 CFR 40.205(b)(2).
In practice, many collection sites will use up existing stock of the 2023 form before switching over. A test on a 2023 form during the transition period is not a problem.
What changed on the form
The revisions are mostly layout and field changes:
Step 1: Drug tests to be performed
The individual drug checkboxes were removed. The field now asks for any other tests to be performed. Collectors do not complete it, because the laboratory knows which tests to run from the account information on the form.
Step 4: Split specimen information
The location of the split-specimen device expiration date field was changed.
Step 5: Donor information
The two separate phone number fields were combined into one. The email line was lengthened, and "Date of Birth" is now labeled "Birthdate."
The revision does not by itself change which drugs are tested in DOT programs or allow oral fluid testing to start. DOT's drug panel and specimen types are set by 49 CFR Part 40.
What the CCF records
Whichever version is used, the CCF documents the key facts of a DOT collection:
- The employer, the MRO and the laboratory account
- The reason for the test, such as pre-employment, random, post-accident, reasonable suspicion, return-to-duty or follow-up
- Whether the collection was observed and the specimen temperature check
- The chain of custody from the donor to the collector to the laboratory
- The donor's certification and contact information, so the MRO can reach the donor if needed
Accurate information on the CCF matters. A wrong employer name, missing test reason or incorrect MRO can delay results or require corrective paperwork.
What employers should do
- Confirm with your collection sites and laboratory that your account information is set up for the 2026 CCF.
- Give drivers the correct employer name and test reason before they go to the collection site.
- If you use an electronic CCF, confirm your provider has updated to the 2026 version.
- Plan to have old paper stock retired well before May 31, 2027.
What drivers should know
For drivers, the collection process itself is unchanged. You still need a photo ID, you still provide a urine specimen under the collector's instructions, and you still review and sign the form. If a DOT test result is non-negative, the MRO will use the contact information on the CCF to reach you, so make sure the phone number you give is correct.
Frequently Asked Questions
Is a test on the 2023 CCF still valid?
Yes. Collections on the 2023 CCF are authorized until May 31, 2027 without a memorandum for the record. After that date, using an old form requires a memorandum for the record.
Does the new CCF mean DOT is testing for fentanyl?
No. The form change does not add drugs to the DOT panel. HHS has added fentanyl to the federal panels, but DOT's proposal to add fentanyl to DOT testing had not been finalized as of late September 2026. See 2026 DOT Drug Testing Changes.
Can the 2026 CCF be used for oral fluid tests?
Not in practice yet. DOT oral fluid testing cannot begin until HHS certifies at least two oral fluid laboratories, and none had been certified as of September 2026. SAMHSA's guidance also notes that CCF versions earlier than 2026 are not authorized for oral fluid specimens.
Does a non-DOT test use the federal CCF?
No. Non-DOT tests should use a non-federal chain-of-custody form. The federal CCF is only for federally regulated testing. Read more in DOT vs. Non-DOT Drug Testing.
DOT collections at Test Pro LLC
Test Pro LLC performs DOT urine collections using current federal forms at our Kent, Washington office. Book a DOT drug test, learn more about DOT drug testing in Kent, or contact us to set up your employer account.