Updated: December 21, 2025
Many DOT-regulated employers assume they are audit-ready because they are enrolled in a drug and alcohol testing program. In practice, DOT audits are not about whether you are enrolled. They are about whether you can produce the right documentation, in the right format, on demand.
This page is designed for employers who want an honest answer to a simple question: if a DOT auditor contacted you tomorrow, would you pass?
Below, we walk through what DOT audits actually review, where most employers run into problems, and how to identify gaps before they turn into violations.
Who This Page Is For
This guidance applies to employers regulated under DOT drug and alcohol testing rules, including FMCSA, FAA, FTA, PHMSA, and FRA. It is written for owners, compliance managers, safety managers, and HR teams who are responsible for maintaining testing records and responding to audits.
If you are responsible for producing documentation during a DOT audit, this page is for you.
What Triggers a DOT Audit?
DOT audits are not random in the way testing selections are. Common triggers include:
- New entrant safety audits
- Compliance reviews following an incident or violation
- Follow-up audits after prior findings
- Random compliance checks by the agency
When an audit occurs, employers are expected to provide documentation quickly. Delays, missing records, or inconsistent files are often treated as compliance failures, even if testing is being performed.
What DOT Auditors Actually Review
DOT audits focus on execution and documentation, not intent. Auditors are looking for evidence that your program operates correctly on an ongoing basis.
Typical audit requests include:
- Random selection records showing how and when employees were selected
- Proof of employee notifications and timing
- Completed test results and refusal documentation
- MIS reports, when applicable
- Supervisor training records
- Records showing required follow-up testing was completed
- Documentation showing employees were correctly added to and removed from testing pools
Auditors also commonly request proof of DOT drug and alcohol supervisor training, particularly when reasonable suspicion or post-accident testing is involved.
Auditors are not asking whether you “have a program.” They are verifying whether the program functions consistently and whether records support that claim.
Being Enrolled vs Being Audit-Ready
This is where many employers run into trouble.
Being enrolled in a consortium or testing program means you have access to testing services. Being audit-ready means you can prove that the program is being managed correctly every quarter.
This distinction is often missed by employers who are enrolled in a DOT consortium but do not have structured processes in place for how random drug and alcohol testing is actually executed and documented.
Common gaps include:
- Missing notification documentation
- Incomplete random selection records
- Employees performing safety-sensitive work who were not in the pool
- Outdated supervisor training records
- MIS reports that do not align with underlying documentation
These issues often surface only during an audit, when it is too late to correct them retroactively.
A Practical DOT Audit Readiness Checklist
Use the questions below as a quick self-assessment.
- Can you produce random selection reports for the last 12 months?
- Do you have documentation showing when employees were notified?
- Can you show that testing was completed within required timeframes?
- Are all safety-sensitive employees correctly included in your pool?
- Are supervisor training records current and accessible?
- Can you generate required MIS reports with supporting records?
If any of these questions create uncertainty, your program may be compliant on paper but not audit-ready in practice.
Where Employers Commonly Fail DOT Audits
Based on audit reviews and compliance support work, the most frequent issues include:
- Assuming a consortium manages documentation automatically
- Relying on email trails instead of structured records
- Inconsistent employee rosters across quarters
- Missing proof of notifications
- Lack of centralized recordkeeping
DOT auditors are consistent in one expectation: if it is not documented, it did not happen.
How PROCOM Supports Audit Readiness
PROCOM supports employers by managing the operational side of drug and alcohol testing programs. This includes helping employers maintain clean, organized records that align with DOT expectations.
Support typically includes:
- Verifying employee rosters each testing cycle
- Maintaining random selection and notification records
- Coordinating collections and tracking results
- Supporting MIS reporting requirements
- Helping employers prepare documentation when an audit occurs
The goal is not just compliance, but confidence when documentation is requested.
This type of operational support is part of PROCOM’s broader compliance and testing services for DOT-regulated employers.
Colorado DOT Audit Example
A Colorado employer enrolled in a testing program believed their audit exposure was minimal. During a compliance review, the auditor requested selection and notification records from prior quarters. While testing had occurred, documentation was incomplete and scattered across multiple systems.
After addressing recordkeeping gaps and implementing a structured management process, the employer was able to respond confidently to future requests and avoid repeat findings.
This scenario is common. Audits rarely fail because testing did not occur. They fail because records do not tell a clear, complete story.
Preparing Before an Audit Matters
DOT audits are time-sensitive. Employers are often given limited windows to respond. Preparing after an audit notice arrives is risky and stressful.
Staying audit-ready also means keeping up with recent DOT drug testing updates, as changes to testing panels, reporting requirements, or procedures can impact what auditors expect to see.
Audit readiness is about maintaining systems that work continuously, not scrambling when a request arrives.
Frequently Asked Questions About DOT Audits
A DOT audit is a formal review conducted by a DOT agency to verify that an employer’s drug and alcohol testing program is operating correctly. Auditors review documentation, testing records, and procedures to confirm compliance with federal regulations.
There is no fixed schedule. Audits can occur as part of a new entrant review, following an incident, after prior violations, or through routine compliance checks by the agency.
Auditors commonly request random selection records, proof of employee notifications, completed test results, MIS reports when applicable, supervisor training records, and documentation showing employees were correctly included in testing pools.
No. Enrollment provides access to testing, but audit readiness depends on whether records are complete, consistent, and available on demand. Many audit findings stem from documentation gaps rather than missed tests.
Common issues include missing notification records, incomplete random selection documentation, employees not properly included in testing pools, outdated supervisor training, and inconsistent MIS reporting.
Auditors may request records covering multiple prior years, depending on the agency and type of audit. Employers are expected to retain records according to DOT retention requirements and produce them promptly when requested.
Preparation involves regularly reviewing documentation, verifying employee rosters, maintaining organized records, and ensuring testing and notifications are documented consistently. Waiting until an audit notice arrives increases risk.
Strengthen Your DOT Audit Readiness
If you are a DOT-regulated employer in Colorado and want to understand where your program stands, reviewing your documentation before an audit occurs is the safest approach.
PROCOM works with employers across Colorado to identify gaps, improve recordkeeping, and reduce audit risk so programs operate as expected year-round.
For in-person support, our teams in Glenwood Springs, Grand Junction, and Pueblo are available. You can also reach out through our contact page to discuss audit readiness and compliance support.
For further information or to learn more about FMCSA’s recommended best practices for DOT random drug and alcohol testing, visit Best Practices. To learn more about the DOT’s recommendation for drug and alcohol record keeping, check out this Record Keeping Guidelines.
