What the 2026 CCF changes
The CCF is the five-copy chain-of-custody document that follows a specimen from the collection site to the laboratory, then to the Medical Review Officer (MRO) and the employer. The Office of Management and Budget approved the revised form effective April 27, 2026, with an expiration date of April 30, 2029.
The revisions are modest and primarily clean up the donor-information sections:
- Step 1F (Copies 1–5): The drug analyte list and checkboxes are gone. The heading now reads “Other tests to be performed (specify):”.
- Step 4 (Copy 1): The “Split Specimen Device Expiration Date” field moved to the right.
- Step 5 (Copies 2–5): The email line is longer and moved right. Separate daytime and evening phone fields are replaced with one “Phone No.” field, and “Date of Birth” is now “Birthdate” and moved left.
One clarification matters for collection sites: collectors do not need to complete Step 1F. The laboratory determines the testing panel from the account number on the form.
The deadline that actually matters: May 31, 2027
The 2026 form does not make the old one instantly invalid. DOT-regulated employers and service agents — including collectors, laboratories, and MROs — are authorized to use the 2023 CCF until May 31, 2027.
Between April 27, 2026 and May 30, 2027, a collector may use a 2023 CCF without a memorandum for the record. Beginning May 31, 2027, use of the 2023 form becomes a correctable discrepancy requiring an MFR under 49 CFR 40.205(b)(2).
SAMHSA has also clarified that the 2020 and 2023 Federal CCFs are the same form. Laboratories may accept either without an MFR until May 31, 2027. Forms older than 2020 are expired and were never authorized for oral fluid collections. ODAPC's practical recommendation is to coordinate the switch with your laboratory as your existing supply runs low.
Mark your calendar: May 31, 2027 is the first day an otherwise valid test using the 2023 CCF creates a correctable discrepancy. Start checking your collection-site and laboratory supplies before then.
Why an expired form can cost you a hire
Under 49 CFR 40.203(d)(3), a collector using a non-Federal form or an expired CCF creates a correctable flaw. The MRO must cancel the test unless the problem is corrected.
The correction is not automatic. Under § 40.205(b)(2), the responsible person must produce a signed memorandum for the record stating that the incorrect form contained the information needed for a valid DOT test, that it was used inadvertently or as the only means of testing in circumstances beyond their control, and what steps will prevent a repeat. It must be supplied the same business day the problem is raised, and the specimen must have been tested at an HHS-certified laboratory.
If the correction does not happen, the MRO must cancel the test. A cancelled test is not a negative. Under 49 CFR 40.207, it is neither positive nor negative, cannot authorize an employee to perform safety-sensitive functions after a pre-employment, return-to-duty, or follow-up test, and does not count toward your minimum random testing rate.
In plain terms, a driver may have to wait for a recollection, your company pays for another test, and a new hire cannot get behind the wheel based on the cancelled result. Some paperwork issues cannot be fixed at all. 49 CFR 40.199 lists fatal flaws such as no CCF, no printed collector name or signature, two collections on one CCF, or specimen ID numbers that do not match.
Let APCA keep the paperwork on track
APCA manages FMCSA consortium programs, collection-site coordination, random selections, results, and records for carriers and owner-operators nationwide. Get help confirming your program is ready for the CCF transition.
The one field FMCSA cares about most
Whichever CCF version your collection site uses, one FMCSA-specific requirement predates the 2026 revision and is still commonly missed on a CDL driver's test.
Under 49 CFR 382.123, for every controlled-substance test performed under Part 382, the employer must provide the driver's commercial driver's license number and state of issuance in Step 1, Section C of the CCF, along with the employer's identifying information in Step 1, Section A. For alcohol tests, the CDL number and state go in Step 1, Section B of the Alcohol Testing Form.
This field helps MROs accurately report violations to the FMCSA Clearinghouse. A missing or incorrect CDL number does not automatically cancel the test, but it can create downstream reporting problems that are much harder to untangle after the fact.
What carriers should do now
- 1Review the official 2026 Federal CCF with the person who manages your testing paperwork, but do not print or use the sample to conduct a DOT drug test.
- 2Ask your collection site and laboratory which CCF version they currently issue and when they expect to switch.
- 3Keep checking that each CDL number and state of issuance are entered in the correct CCF section.
- 4If you use a C/TPA, ask how the transition will be handled and whether your collection network is ready.
- 5Plan to run down older form supplies before May 31, 2027 — but do not use any form older than the authorized versions.
The bottom line
Nothing about the 2026 CCF requires you to change how you run your program today. Confirm that your collection site and laboratory know the switchover date, make sure the driver's CDL number and state are on every CCF, and treat an expired form as a preventable expense.
If you use a C/TPA, this transition should be handled as part of your program support. It is still worth asking which form your network is currently issuing and how the move to the new CCF will be managed.
Reference sample
View a Sample of the New Federal CCF
This sample is for reference only. Do not print or use it to conduct a DOT drug test. Authorized collection sites and laboratories provide the correct CCF through their approved systems.
View sample PDFFrequently asked questions
Do I have to stop using the 2023 CCF right now?
No. ODAPC has authorized DOT-regulated employers and service agents to use the 2023 version until May 31, 2027. No memorandum for the record is required when the 2023 CCF is used through May 30, 2027, as long as the form is otherwise completed correctly.
What happens if a driver's test uses an expired CCF after May 31, 2027?
Use of an expired CCF becomes a correctable flaw under 49 CFR 40.203. The responsible person must provide a same-business-day memorandum for the record that meets the requirements of 49 CFR 40.205(b)(2). If the problem is not corrected, the Medical Review Officer must cancel the test and the driver will need a recollection.
Does a cancelled test count as a negative for a pre-employment hire?
No. Under 49 CFR 40.207, a cancelled test is neither positive nor negative. It cannot authorize an employee to perform safety-sensitive functions after a pre-employment, return-to-duty, or follow-up test, and it does not count toward the employer's minimum random testing rate.
Is the electronic CCF the same form?
Yes. The 2026 Federal CCF may be used as a paper form, an electronic form, or a combination of both. Electronic CCF availability depends on the collection site and laboratory, so ask your provider whether they are ready to support it.
Do I need to write the drug panel on the form?
No. Collectors do not need to complete Step 1F. The laboratory determines the testing panel from the account number on the CCF.
Sources
Questions about your DOT drug testing program? APCA is a USCG- and FMCSA-approved T/CPA serving mariners and safety-sensitive transportation workers nationwide. Call (727) 522-2727 or contact our team.