What Do Collection Sites Need to Know About the 2026 Federal CCF?

Collection sites, clinics, and TPAs must track which Federal Custody and Control Form (CCF) version is in the kit and when older stock needs an accompanying memorandum for the record (MFR). DOT's Office of Drug and Alcohol Policy and Compliance (ODAPC) published a notice on the revised 2026 Federal CCF. The dates and collector duties below come from that notice.

Effective dates

• The revised 2026 Federal CCF may be used as a paper or electronic form. Its effective date is April 27, 2026. The OMB approval on the notice runs through April 30, 2029.
• DOT-regulated employers and their service agents (collectors, laboratories, MROs) are authorized to use the 2023 version of the CCF until May 31, 2027.
• Between April 27, 2026 and May 30, 2027, if the 2023 CCF is used, an MFR is not required.
• As of May 31, 2027, if the 2023 CCF is used, an MFR must be completed per 49 CFR 40.205(b)(2).

ODAPC recommends coordinating delivery of the revised 2026 CCF with the laboratory when existing 2023 stock is about to run out, rather than discarding usable forms early.

What changed on the form

According to ODAPC's notice, the revised CCF includes these layout and wording changes:

• In Step 1F (copies 1 through 5): drug analytes and checkboxes were removed, and the field label changed to "Other tests to be performed (specify):".
• In Step 4 (copy 1): the Split Specimen Device Expiration Date field moved to the right.
• In Step 5 (copies 2 through 5): the email line was lengthened and moved, the daytime and evening phone fields were replaced with a single Phone No. field, and the date of birth field was reworded as Birthdate and repositioned.

Do collectors complete Step 1F?

ODAPC's notice states that collectors do not need to complete Step 1F. The laboratory knows the drug testing panel from the account number on the CCF. Collectors should not enter the drugs to be tested in that field as a routine step.

There is no separate DOT "CCF course" requirement. Correct CCF completion is already part of urine collector qualification training under 49 CFR 40.33(b)(1), which requires instruction on all steps necessary to complete a collection correctly and the proper completion and transmission of the CCF. Sites updating staff on the 2026 layout can treat that as refresher content inside existing collector training, not as a new credential.

Site checklist

• Confirm which CCF version is in active kits and in storage.
• Plan the switch to 2026 forms with the laboratory before May 31, 2027 if 2023 stock will still be in use after that date.
• Brief collectors that Step 1F drug checkboxes are gone on the 2026 form and that they do not fill drug panels there.
• Keep current DOT urine collection procedure guidelines available to collectors. ODAPC updated the Urine Specimen Collection Procedures Guidelines in June 2026.

For how collector qualification and documentation fit around form changes, see qualified specimen collector requirements, what 49 CFR Part 40 covers, and when error correction training is needed.

Organizations updating collector staff can enroll through a Training Manager account in DOT Urine Specimen Collector Training or DOT Urine Error Correction Training.