Thank you to NDASA board member George Gilpatrick, a senior auditor and team leader for the Federal Transit Administration (FTA) Drug & Alcohol Compliance Auditing Program, for providing this valuable information during a recent NDASA Member’s Memo podcast.
Providing collection services is often a complicated task when it comes to the variety of clients and their multiple expectations.
Many clients don’t fully understand the regulations or capabilities of a test, and the process of the collection itself. While a collection site may seem like a narrow niche business, the reality is that they are often a centralized location for innumerable and sometimes conflicting protocols and expectations. Being able to use diplomacy, establish trust or communicate a convincing insistence may be part of the collection process with many of your customers.
6 Steps
Here are six steps you can take to make it easier for everyone:
1. Make sure you have updated contact information for every Designated Employer Representative (DER), and updated protocols about who to communicate with. If you only have the general number or even the number or email for an employer’s Third Party Administrator (TPA) for example, you as a collector may not be able to effectively communicate issues like refusals breath alcohol positives and dealing with uncooperative employees. Let each client know that you need the best phone number for them in case you need direct voice contact during the test. Ideally, you should have several numbers for the client where they can be easily reached.
2. Call the employer or DER to double check if you are in doubt about protocol. For example, an employer has sent an employee in for a federal Return to Duty (RTD) test, but it’s not indicated on a notification form that the test is to be under direct observation. A quick phone call to gently remind them of this requirement is appropriate. Often, you will find in these cases that the employer is not actually requesting an official RTD because of a failed test or test refusal, but rather, that an employee is returning to their duties after a long absence and therefore, may need a Pre-Employment test. A true RTD test means that the employee is returning after a violation. For most regulated employers, an employee returning to their job after a long absence may require a Pre-Employment test.
3. Give uncooperative donors a calm explanation of the possible consequences for their actions. While it is not required, it is advisable to give the uncooperative employee fair warning that their behavior may cause the test to end and that this may result in their employer (not you, the collector) considering their actions a refusal to test, which is a de facto positive. Make sure to document the entire interaction immediately afterward and be as thorough as possible. You can also have the employee speak directly to their DER to hear it from the actual authority on the matter. This is exactly the kind of issue that can come up for which you must have the best current contact information for your client. Check out NDASA’s Conflict Mitigation Training for more information on how to deal with difficult situations.
4. Take appointments or encourage your employers to call or text ahead if they are sending people for testing. Even a rough estimate of how many employees are coming and at what time will help you arrange your day, and maybe reallocate personnel or resources to deal with it. This makes the process more efficient for everyone and will allow employees to return to work as quickly as possible.
5. Read the regulations. Staying current with the Department of Transportation’s language in 49 CFR Part 40 will put meaning and background into your procedures. For example, understanding the actions that constitute a refusal will make your conversations with your clients and DERs much easier. It mitigates the potential for conflict when they know that you are speaking about requirements and not your own preferences. If you perform unregulated tests, contact each device maker or laboratory and ask for their usage instructions or their device protocols and treat those as the regulations. In the absence of a regulation, a manufacturer guideline is probably the best authority.
6. Streamline your sign-in process. There are many new and innovative ways to complete all the required or desired paperwork for donor intake at the collection site. Consider going electronic and allowing individuals to sign in through an app, by using a tablet or have clients requisition tests with QR or bar codes, so that all the information you need is available in advance. Having staff manually enter names and information into a computer often occupies more time than the test itself. For walk-in clinics that offer other testing, it is helpful to review the testing processes for different types of tests. For example, drug and alcohol testing is often exempt from some insurance or HIPAA paperwork requirements. This is not always the case, but it can certainly save hours each day if the employee has five fewer sheets of paper to fill out on the clipboard. How does this help your client? Again, when the employee gets back to work sooner, you are benefitting the employer’s bottom line.
All of these are simple steps that can be accomplished in minimal time, and the benefits will be apparent to you and your clients. For more information on how to improve the collection process, visit the NDASA website, listen to our podcast, read our blog series or take an NDASA training.