CLP or No CLP - that's the key starting point.
No CLP or CDL yet? The student is completely outside the scope of 49 CFR Part 382. Any drug test a school administers to them is not a DOT drug test, they don't register in the Clearinghouse, and they don't need a TPA. Any drug testing performed at this point is NON-DOT and will not effect your Clearinghouse status.
Once you obtain a CLP? Federal drug and alcohol testing rules kick in immediately and fully. This is where the rules get more involved.
Student is already Employed
Student is employed by a motor carrier while training. The motor carrier is the employer of record, handles all drug testing, registers the student as a regular driver in the Clearinghouse, and manages TPA enrollment if they use one. The school has no compliance role here, and the student does not need to enroll with an outside TPA / Consortium.
Student is enrolled with a driving school and is not currently employed (with a motor carrier)
This is the most common situation and the biggest source of confusion. The student holds a CLP but has no employer. In this case:
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The student must register in the FMCSA Clearinghouse as a "Student Driver"
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They must designate a C/TPA (Consortium/Third-Party Administrator) to manage their drug and alcohol testing obligations — they essentially act as their own "employer" through the TPA
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A pre-employment (technically "pre-safety-sensitive-function") drug test is required before they can operate a CMV in commerce
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The independent school itself can register as a C/TPA and provide those services, OR the student can go find their own TPA