Do the drug and alcohol rules apply to pilot programs that do not use any FTA funds?

Yes. Previously, FTA under certain circumstances permitted an exemption from FTA’s drug and alcohol rules for up to one year for pilot programs run by public transit agencies. FTA has discontinued that exemption, with the exception of allowing already-existing pilot programs that were making use of the exemption to complete their one-year exemption period. Apart from that exception, if a transit agency subsidizes ridesourcing services, the transit agency must either design the service such that the taxicab exception applies, or incorporate the ridesourcing company drivers into the drug and alcohol program.