You can begin the SAP process without an employer.
Your employment status changes the later test handoff. FMCSA provides a limited path for qualifying CDL drivers.
The SAP evaluation comes first.
The SAP can evaluate you and recommend education or treatment even if you are not currently working. The follow-up evaluation occurs after you complete the recommendations; only a successful compliance determination makes you eligible for the RTD test.
FMCSA says that when a driver has no current or prospective Part 382 employer to send them for an RTD test, the driver may register with the employer role as an owner-operator and designate a C/TPA for the limited purpose of completing the RTD process. The C/TPA can direct the test and report a negative result.
FMCSA says not to apply for a USDOT number solely to use this option. A future employer administers the SAP’s follow-up testing plan once safety-sensitive work resumes.
Read the FMCSA FAQ before taking this step ↗