Oral fluid gets most of the headlines, but several other changes are moving through the federal drug testing system. Here's where things stand.
Fentanyl: in place for HHS, proposed for DOT
HHS added fentanyl and its metabolite norfentanyl to the federal workplace drug testing panels, effective July 7, 2025. Because DOT's panel follows the HHS guidelines, DOT published a proposed rule on September 2, 2025 to add fentanyl to its urine and oral fluid panels and norfentanyl to its urine panel. As of this writing, that rule has not been finalized. Until DOT publishes a final rule and it takes effect, DOT tests continue to use the current panel.
Other changes in the same proposal
The proposal would also align several items with the HHS guidelines, including an adjustment to the urine morphine confirmatory cutoff, authorization of biomarker testing and changes to MRO review of certain opioid results. It also proposes a 30 day window for collectors, screening test technicians and breath alcohol technicians to complete required training and mock collections.
The 2026 Federal CCF
SAMHSA has released a 2026 Federal Custody and Control Form. Changes include removing the drug analyte checkboxes in Step 1F along with some layout updates. After May 31, 2027, using the 2023 form becomes a correctable flaw, so collectors should get comfortable with the new form now.
What this means for your program
• Policies: plan to update your panel language when DOT finalizes the fentanyl rule.
• Collectors: learn the 2026 CCF now.
• Supervisors and DERs: fentanyl awareness belongs in reasonable suspicion training and employee education.
• Everyone: watch transportation.gov/odapc for final rules and effective dates.
Stay ahead with Stratellis Training
Our collector, supervisor and DER courses are maintained as federal requirements change, and we can build custom training for your team. Explore our courses or reach us at sales@stratellistraining.com.