Frequently Asked Questions About Federal Workplace Drug Testing

See (Mandatory Guidelines – Urine) and (Mandatory Guidelines - Oral Fluid).

No. The Mandatory Guidelines for Federal Workplace Drug Testing Programs do not address the question of fitness for duty.

Source: DWP Staff, 240-276-2600

The Mandatory Guidelines for Federal Workplace Drug Testing Programs provide the scientific and technical structure for the drug testing of employees in all civilian positions in Executive Branch agencies. Among these are positions that affect public safety, public health, or national security in which even a momentary lapse of attention or judgment could result in significant harm and are therefore designated for random drug testing. Revisions to the Mandatory Guidelines are intended to enhance public safety. See (Guidance for the Selection of Testing Designated Positions (PDF | 262 KB)).

No. The Mandatory Guidelines for Federal Workplace Drug Testing Programs do not cover non-federal employees. They address only federal civilian employees and federal agencies required by law to use the Mandatory Guidelines for Federal Workplace Drug Testing Programs (e.g., the Department of Transportation and Nuclear Regulatory Commission. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines - Oral Fluid), Section 3.4.

Source: DWP Staff, 240-276-2600

Revisions to the Mandatory Guidelines for Federal Workplace Drug Testing Programs cover all civilian employees in Executive Branch agencies. Employees should contact their federal agency employer or refer to their employer’s (agency’s) Drug-Free Workplace Program plan to learn how these revisions will affect them or their agency.

Source: DWP Staff, 240-276-2600

To continue serving as an MRO for federal agency specimens, certified MROs must have completed training prior to the October 1, 2017 effective date. See (Mandatory Guidelines – Urine), Section 13.3.

To continue serving as an MRO for federal agency specimens, certified MROs must have completed training prior to the October 1, 2017 effective date. See (Mandatory Guidelines – Oral Fluid).

The Mandatory Guidelines for Federal Workplace Drug Testing Programs using Urine (UrMG) were effective February 1, 2024, and the Mandatory Guidelines for Federal Workplace Drug Testing Programs using Oral Fluid (OFMG) were effective October 10, 2023. Major changes were:

1. Revisions to the timeline and procedures for drug testing panel changes (i.e., drugs, analytes, and cutoffs)
2. Revisions to report specimens as substituted based on biomarker testing (i.e., concentration inconsistent with that established for human specimens)
3. Establishing a timeline and process for publishing an authorized biomarker testing panel (i.e., biomarker analytes and cutoffs)
4. Revisions to the Medical Review Officer (MRO) verification process for positive codeine and morphine specimens
5. Adding requirements for MROs to submit semiannual reports to SAMHSA on federal agency specimens that were reported as positive for a drug or drug metabolite by a laboratory and verified as negative by the MRO
6. UrMG: Raising the morphine confirmatory test cutoff for urine from 2,000 ng/mL to 4,000 ng/mL

The Drug Testing Advisory Board (DTAB) advises the Assistant Secretary for Mental Health and Substance Use, SAMHSA, based on an ongoing review of the direction, scope, balance, and emphasis of the agency’s drug testing activities and the National Laboratory Certification Program (NLCP). See (Drug Testing Advisory Board).

The DTAB reviews the NLCP for federal workplace drug testing programs as required by Public Law 100-71 and as described in the Mandatory Guidelines for Federal Workplace Drug Testing Programs. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid). It recommends areas for emphasis or de-emphasis, new or changed directions, and mechanisms or approaches for implementing recommendations. Periodically, the Board reviews specific science areas on new drugs of abuse and the methods necessary to detect their presence.

Source: Drug Testing Advisory Board (DTAB).

For information about DTAB meetings, please see the list of DTAB meetings at: (Advisory Council Meetings). When available, a link to register to attend the next open DTAB meeting, can be found at: (SAMHSA NACRegister). For further information about DTAB, please go to (Drug Testing Advisory Board). If there are further questions, please contact DWP (dwp@samhsa.hhs.gov or 240-276-2600).

Source: DWP Staff, 240-276-2600

The DTAB meeting schedule can be found at the SAMHSA Advisory Council Meetings webpage at (Advisory Council Meetings).

No. Effective January 1, 2020, a federal agency may collect an oral fluid specimen for its workplace drug testing program. Oral fluid and urine are the only specimen types currently authorized for collection by the Mandatory Guidelines for Federal Workplace Drug Testing Programs. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid).

See: 2020 Election and Changes in State Drug Laws (PDF | 526 KB); 2012 New State Initiatives Passed on Use of Marijuana for "Recreational" Purposes (PDF | 66 KB); and Marijuana, Marijuana Oils, Marijuana Infused Products and Hemp Products (PDF | 755).

Specimens must be collected by a trained collector in accordance with the collection procedures outlined in the HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs and the HHS Specimen Collection Handbook. A split specimen collection is conducted (i.e., the donor’s specimen is divided into the primary specimen, A and split specimen, B). Testing must be performed at a laboratory certified by HHS under the National Laboratory Certification Program (NLCP). Laboratory results are reviewed and reported by a certified Medical Review Officer (MRO). Provision for testing the split (B) specimen adds a further safeguard.

Source: DWP Staff, 240-276-2600

The misuse and abuse of psychotherapeutic prescription drugs, including opioid pain relievers, are issues of concern for all populations regardless of age, gender, ethnicity, race, or community. Opioid-related overdose deaths in the United States now outnumber overdose deaths involving all illicit drugs (e.g., heroin and cocaine) combined. See (Overdose Death Rates | National Institute on Drug Abuse). In addition to overdose deaths, emergency department visits, substance treatment admissions, and economic costs associated with opioid abuse have all increased in recent years.

The Mandatory Guidelines for Federal Workplace Drug Testing Programs and the Federal Drug-Free Workplace Program are deterrents to illicit use of opioid drugs and encourage federal civilian employees to seek treatment for opioid use disorders. The Mandatory Guidelines for Federal Drug Testing Programs framework with partners at the federal, state, and local levels to implement policies and programs to reduce prescription drug misuse and improve public health. Specifically, the Mandatory Guidelines for Federal Drug Testing Programs provide for screening for illicit opioid use among federal and civilian employees in safety and security sensitive positions.

Source: DWP Staff, 240-276-2600

The inclusion of the four most commonly misused Drug Enforcement Administration (DEA) Schedule II prescription medications (i.e., oxycodone, oxymorphone, hydrocodone and hydromorphone) in the list of authorized drug tests was recommended by the DTAB, reviewed by the Department of Health and Human Service’s Prescription Drug Subcommittee of the Behavioral Health Coordinating Committee, and approved by the SAMHSA Administrator in January 2012.

The inclusion of oxycodone, oxymorphone, hydrocodone and hydromorphone in the Mandatory Guidelines for Federal Workplace Drug Testing Programs for urine or oral fluid drug testing is supported by various data and seen in private sector experiences with current drug abuse trends. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid). HHS is continuing its efforts to prevent opioid addiction in support of combating the opioid crisis. Implementing these revised guidelines will help ensure safety in the federal workplace and national security, public health, and public safety occupations.

Source: DWP Staff, 240-276-2600

Yes. The 6-acetylmorphine (6-AM) heroin metabolite is included in the Authorized Drug Testing Panel. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid), Section 3.4.

Testing for the synthetic opioid, fentanyl, is not included in the Authorized Drug Testing Panel at this time.

The term “opiates” is used to describe naturally occurring alkaloid substances derived from the opium poppy plant (e.g., codeine and morphine) that bind to specific receptors in the central nervous system and have analgesic as well as narcotic effects. Heroin is a semi-synthetic opioid that is manufactured by acetylating morphine.

The term “opioids” has expanded in scope over time and is broadly used to describe various compounds that bind to opioid receptors in the central nervous system and have analgesic as well as narcotic effects. The term “opioids” includes naturally occurring alkaloid compounds known as opiates (e.g., codeine and morphine); semi-synthetic compounds (e.g., heroin, oxycodone, oxymorphone, hydrocodone, and hydromorphone); and synthetic compounds (e.g., fentanyl). Opioids may or may not have structural similarity to the opium alkaloids. See (Medical Review Officer Guidance Manual), Appendix A: Glossary.

Positive drug test results that are explained by a legitimate medical explanation, such as a valid prescription, will not be reported to a federal agency. See (Medical Review Officer Guidance Manual), Chapter 4.5.

Yes.

Source: DWP Staff, 240-276-2600

No. An HHS change to the Authorized Drug Testing Panel (e.g., addition or removal of a drug, changed initial or confirmatory test analyte, changed initial or confirmatory test cutoff) is not considered a “substantive change” to an agency’s plan.

A “substantive change” is any alteration to a federal agency’s drug-free workplace plan that affects the substance of the plan’s policy and/or procedures, such as adding or eliminating applicant testing. It does not refer to purely editorial changes, administrative updates, or exercises of authority under the Mandatory Guidelines for Federal Workplace Drug Testing Programs. Federal agencies should consult with their legal counsel and labor and employee relations staff to determine the impact of any changes on collectively bargained agreements and should contact DWP staff (dwp@samhsa.hhs.gov or 240-276-2600) to receive tailored guidance that is specific to their plans.

Source: DWP Staff, 240-276-2600

No. HHS will publish the Authorized Drug Testing Panel in the Federal Register on an annual basis. A federal agency can request an HHS waiver to test for any Schedule I or II drug routinely, or can test a post-accident or reasonable suspicion specimen for a specified Schedule I or II drug on a case-by-case basis. See (Mandatory Guidelines – Urine), Sections 3.1 and 3.4 and (Mandatory Guidelines – Oral Fluid), Sections 3.1 and 3.4.

See 2020 Election and Changes in State Drug Laws (PDF | 526 KB) and 2012 New State Initiatives Passed on Use of Marijuana for "Recreational" Purposes (PDF | 66 KB).

Source: DWP Staff, 240-276-2600

See Marijuana, Marijuana Oils, Marijuana Infused Products and Hemp Products (PDF | 755 KB) and Use of Marijuana Oils or Marijuana Infused Commercial products (PDF | 252 KB).

Source: DWP Staff, 240-276-2600

Consult with your agency’s Ethics Office, Office of General Counsel, Human Resources, and Office of Safety and Security regarding your specific situation.

Source: DWP Staff, 240-276-2600

Consult with your agency’s Ethics Office, Office of General Counsel, Human Resources, and Office of Safety and Security regarding your specific situation.

Source: DWP Staff, 240-276-2600

There is no official definition at this time. There is, however, significant public discussion around marijuana, much of which includes the terms legalization, decriminalization, and medical marijuana. See: (DEA Marijuana Factsheet) (Marijuana is listed under DEA CSA 7360 as Cannabis, marijuana) and (DEA clarification of the new drug code) (7350) for marijuana extract.

The compound tested and reported in urine is delta-9-tetrahydrocannabinol-9-carboxylic acid or THCA. The compound tested and reported in oral fluid is delta-9-tetrahydrocannabinol (THC). See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid).

A federal job applicant or employee can expect their specimen to be collected by a trained professional in a limited access collection setting. The collector will explain the collection process to the donor. See (Mandatory Guidelines – Urine), Subpart H and (Mandatory Guidelines – Oral Fluid).

The following privacy requirements apply when a donor is providing a routine urine specimen:

1. Only authorized personnel and the donor may be present in the restricted access area where the collection takes place.
2. The collector is not required to be the same gender as the donor.
3. The collector must give the donor visual privacy while providing the specimen. The donor is allowed to provide a urine specimen in an enclosed stall within a multi-stall restroom or in a single person restroom during a monitored collection. See (Mandatory Guidelines – Urine) Subpart H.

1. The procedure for a direct observed urine collection is the same as that for a routine collection, except an observer watches the donor urinate into the collection container. The observer must be the same gender as the donor with no exception to this requirement.
2. The gender of the observer for purposes of a direct observed collection must be the same as the donor’s gender, which is determined by the donor’s gender identity.
3. The collector for an observed collection asks the donor to identify the donor’s gender on the Federal Custody and Control Form (CCF) and initials it. The collector then selects an observer whose gender matches the gender of the donor (as recorded on the Federal CCF).
4. The observer must be trained in direct observed specimen collection, but is not required to be a trained collector.
5. The collector documents the observer’s name and gender on the Federal CCF.

See (Mandatory Guidelines – Urine), Sections 4.4 and 8.10 .

1. The procedure for a direct observed urine collection is the same as that for a routine collection, except that a monitor accompanies the donor into the restroom to check for signs that the donor may be tampering with the specimen. The monitor remains in the restroom, but outside the stall, while the donor provides the specimen.
2. The monitor is not required to be a trained collector.
3. The gender of the monitor for a monitored collection must be the same as the donor’s gender, unless the monitor is a medical professional (e.g., nurse, doctor, physician's assistant, technologist, or technician licensed or certified to practice in the jurisdiction in which the collection takes place).
4. If the monitor is not a medical professional (as described above), the collector asks the donor to identify the donor’s gender on the Federal Custody and Control Form (CCF) and initials it. The collector then selects a monitor whose gender matches the gender of the donor (as recorded on the Federal CCF).
5. The collector documents the monitor’s name on the Federal CCF. If the monitor is not a medical professional (as described above), the collector also documents the monitors’ gender.

See (Mandatory Guidelines - Urine), Section 8.12

The collector notifies the federal agency for authorization to collect an oral fluid specimen or follows the federal agency’s standard protocol. If authorized, the collector will proceed with collection of another authorized specimen type (i.e., urine or oral fluid). If the federal agency does not authorize the alternate specimen type, the collector stops the collection and reports the donor’s inability to provide a sufficient specimen to the federal agency and the MRO. The MRO notifies the federal agency to direct the donor to obtain an evaluation from a licensed physician acceptable to the MRO of any pre-existing condition that prevented or will prevent the applicant or employee from providing a sufficient specimen (i.e., urine or oral fluid) for drug testing. The MRO may conduct the evaluation if qualified. Depending upon the MRO determination based on the medical evaluation, further actions may be warranted.

See (Medical Review Officer Guidance Manual), Section 6.2, (Mandatory Guidelines – Urine), Sections 8.5, 8.6, and 13.6 and (Mandatory Guidelines – Oral Fluid).

Observed Collections: When an observed collection is conducted, the observer is the person assigned to physically observe the collection of the specimen. The observer’s gender must be the same as the donor’s (which is based on the donor’s gender identity). The observer is not required to be a trained collector but must be trained as an observer. An observed collection is the same as a routine collection except the observer is in the restroom or stall and watches the donor urinate into the collection container. The observer maintains visual contact with the specimen until the donor hands the container to the collector. The collection container cannot be handled by the observer unless the observer is also serving as the collector.

Monitored Collections: When a monitored collection is conducted, a monitor is the person assigned to monitor collection of the specimen. The monitor’s gender must be the same as the donor’s (which is based on the donor’s gender identity) unless the monitor is a medical professional. The monitor is not required to be a trained collector. It is the same as a routine collection, except the monitor provides visual privacy while being alert for signs of tampering. The monitor must not touch or handle the collection container (unless the monitor is also serving as the collector) and must not watch the donor urinate into the collection container.

See (Mandatory Guidelines – Urine), Section 4.4 and (Medical Review Officer Guidance Manual), Appendix A: Glossary.

The first Mandatory Guidelines for Federal Workplace Drug Testing Programs using Oral Fluid became effective January 1, 2020. Source: (Mandatory Guidelines – Oral Fluid) and (Mandatory Guidelines – Urine).