By Colleen Wienhoff & Melody Paris, Wienhoff Drug Testing
Working toward compliance should be the driving force behind all Consortium/Third Party Administrators (C/TPA) and their services. In the ever-changing drug testing industry, C/TPAs must be diligent to maintain compliance for themselves and their clients. There are several practices C/TPAs can employ to support this goal. These include everything from contracts and certifications to training for both collectors and clients.
No matter how big your business is, you will inevitably need to use another collection site at some point. Whether it is a post-accident test for a client deep in the Heartland, a random test for an owner/operator who is traveling across the sandy plains of Nevada, or a pre-employment test from another state entirely, your clients will find themselves in need of a local site that can provide collection-only services. There are things you, as their C/TPA, will need to do to send your clients to those sites.
Collection site agreements
A good practice to implement is to create a collection site agreement completed in advance by any collection site with which you expect to do business. A collection site agreement should include pricing for collection services, indicate whether the collection site alters forms and any additional fees, and specify whether the site performs electronic collections and, if so, which ones. In addition to the agreement, you will also need to get copies of all collector certifications for that site. Make it a habit to check in periodically with these sites to make sure your information is up to date. Keeping current records will save you time and money when the need arises unexpectedly. Staying in regular touch also builds good relationships with those sites and may lead you to be able to provide reciprocal services for them.
Authorization forms
All collectors at all collection sites appreciate authorization forms, also known as letters of introduction. To ensure your clients are completing the testing they want and need, encourage them to use an authorization form when sending their employees to test with you or any other collection site. Manually created authorization forms need to include the following information:
- Employer name, address, phone number and DER name
- C/TPA name, address, phone number, and email address
- MRO name, address, phone number, fax number, and email address
- DOT module
- Donor name
- Requested test(s)
- Reason for test
- Laboratory name and account number
- Fax numbers or email addresses for where to send billing and results
- Additional information on the donor that is not required but is appreciated:
- Driver’s license number
- Date of Birth
- Phone number
- When available, bar codes for electronic collections are greatly valued. It is critical that you confirm if a collection site does electronic testing and which programs they use before generating a form.
Training & certification
As a collection site, it is imperative to keep your collectors up to date with all certifications. This will help your collectors work more efficiently and effectively. Before they ever do a collection, they should have completed at least eight hours of in-classroom DOT Urine Specimen Collection Training and an additional eight hours of DOT Breath Alcohol Training along with the requisite mock tests. For maximum performance, collectors should be guided through on-the-job training for at least two weeks. It would also benefit all collectors to go through Designated Employer Representative Training and Supervisor/Reasonable Suspicion Training. These classes will help your collectors understand the scope of the job and the needs of your clients more fully. Furthermore, collectors need to complete refresher training. Even though collectors are constantly conducting collections, it is too easy to forget to follow through with the details or to fall into bad habits. Suggestions to help with this are to schedule regular training sessions, have periodic meetings with your collectors—like a town hall— to discuss issues, send out reminder emails on specific items, or ask challenge questions to see if your collectors are keeping up to date on regulations. Keep your collectors engaged so they will understand what is needed and be confident in approaching you with any questions. Your system of training and certification can always benefit from opportunities to teach and will help you in all areas of your business.
Client education
Helping your clients stay in compliance isn’t only about training your collectors. It is also essential to provide learning opportunities for your clients. Supervisor/Reasonable Suspicion Training courses are compulsory for all DOT modules. It is beneficial for your business if you can offer opportunities for your clients to go through Designated Employer Representative (DER) Training or Supervisor/Reason Suspicion Training. Even if you can’t provide the training yourself, there are companies that you can partner with for online or in-person training. In addition to training, keeping your clients informed through written communication, whether emails, newsletters, or posts on your website or social media, allows you to share updates in regulations, changes in your services, or important announcements. Not all clients will take advantage of these opportunities, but those who do will be grateful to you for all your efforts.
Useful resources for you and your clients are the many applications that allow for online meetings and webinars. With Google Meets, Zoom, Microsoft Teams, and more, the ability to share information en masse is easier than ever. A popular webinar for our clients has been the FMCSA Clearinghouse webinar. Even five years after its inception, many companies have not registered for the FMCSA Clearinghouse and this webinar allows us to help several of them at a time with the registration process and teach them how to use the site. Oral Fluid Testing has been a hot topic for some time now, and the ever-changing landscape of that topic leaves so many DOT companies confused and wanting answers. Through live webinars, important information, difficult questions, and complicated answers can be discussed and also provide space for clients to ask, assess, and share their takes.
Client resources
Training opportunities are great, but offering print resources can be greater. Two of our most requested forms are a checklist for Driver Qualification files and the company checklist for DOT audits. These lists are not just helpful for clients, but also helpful for you. Providing such lists to the client allows them to be prepared for the inevitable audit and helps to keep them organized for testing and compliance. The benefit to you is that you can use the lists to ensure that you are providing all the necessary compliance forms to your clients. It can also save you time when your clients utilize those forms and they don’t need to ask you for more items at every audit. There are many sample forms that benefit the client, such as DOT Drug and Alcohol Policies, Employee Limited Query Consent forms, Motor Vehicle Report Forms, etc. If you do not already have these forms available for your clients, many can be found online. Any sample forms or organizational suggestions you have for your clients make the job of the DER easier and more effective. Consider supplying any helpful signs that your clients can use, for example, information on CBD or voluntary self-admission. There are so many rules and regulations that your clients must follow, and they rely on you to ensure they have the know-how and wherefore to comply.
Following best practices and keeping your clients informed can help them traverse the complexities of DOT rules and regulations. Even after doing all of these things, problems will still arise. What these practices will do is allow you, your collectors and your clients to be more adaptable when that happens. There is truth in the old adage “knowledge is power,” and the more power you and your clients have, the more you will ultimately be able to achieve the goal of all C/TPAs, and that is compliance.