Scenarios for DER’sWhat Do I Do?

Presented by: George Gilpatrick and Joe Lofgren

Selections

Selections

Problem:

-You receive a selection list with names of people no longer employed

Selections

Solution:

-Check your roster first

-Call the person in charge of the selection list

-Fix it immediately

Selections

Problem:

-You are told to complete all testing by a certain date, but the new selection list doesn’t arrive until several days/weeks after testing ends

Selections

Solution:

-Demand that it be immediately fixed

or

-FIRE THE VENDOR

Selections

Problem:

-You don’t receive a selection list at all

and there is no additional correspondence from the vendor

Selections

Solution:

-Demand that it be immediately fixed

or

-FIRE THE VENDOR

Selections

Problem:

-You don’t conduct enough random testing by the end of the year

Selections

Solution:

-Note why the testing was not complete

-If you are in a consortium, disregard

-Complete the MIS honestly, email FTA

The Draw

The Draw

Problem:

-Your name appears on the selection list

The Draw

Solution:

-Immediately notify the TPA, and modify the protocol for notification

-If protocol had not been established or followed, a genuine notification did not occur

Notifications

Notifications

Problem:

Your TPA sends you a list of individuals to be tested, but the times they sent are nearly impossible

Notifications

Solution:

-Discontinue having the TPA send testing times that are specific to individual (but consider allowing them to suggest under- represented time blocks)

Sending Employees For Testing

Sending Employees For Testing

Problem:

-You don’t have the personnel to escort employees to the collection site

Sending Employees For Testing

Solution:

-Closely monitor the notification time and arrival time (which may legitimately differ from the testing time)

The Collection Site

The Collection Site

Problem:

Your employees arrive promptly, but have long waits before they are tested

The Collection SitePossible Solutions:

-Request special consideration

-Request honoring of appointments

-Request expedited testing for Post- Accident and Reasonable Suspicion

The Collection Site

-Consider on-site testing

-Financial Incentive: extra cost may be net gain with saved time

The Collection Site

Problem:

-Your collection site opens after your service begins, and closes before your service ends

The Collection SitePossible Solutions:

-Request special consideration per test

-Schedule tests ahead of time

-Ask a single collector to provide the service

-Ask FTA for assistance

Post-Testing

Post-Testing

Problem:

Your test results are slow to arrive (>4 days)

Post-Testing

Likely Causes for Delay:

-Collector not transmitting Copy 2 of CCF

-MRO verifying test results - should not cause systematic delays

Post-TestingSolution:

-Only pay for completed testsWithhold payments to collection sites, TPA’s, and other vendors until you have a complete test

--The collection of the specimen is only the half-way point of the testing process--

Anatomy of a Completed Test1. Employer Copy of the CCF or ATF

2. MRO-verified result (non-verbal)

3. Errors corrected (if applicable)

If you don’t have all of these, the test is NOT complete. Consider this when you receive the invoice.

Documents Receivable

Documents Receivable

The employer copy of the CCF (Copy 4 – Blue Copy)

Complete in Steps 1-5

Legible

Documents Receivable

The MRO-confirmed results

Information corresponds to testing form, includes dates, time, donor (or ID #), results, and specimen number

Documents Receivable

Corrective affidavits or explanations from vendors

Acknowledgement of errors with reason

Incomplete information completed or corrected

If fatal, proof of error-correction

The MRO

“Hello, [DER]… this is Dr. Ackerly. I need to get in touch with one of your employees, and I’m having trouble contacting them. Can you please contact them and ask them to call me immediately? My number is…”

What do you do?

The MRO

“Hello, [DER]… this is Dr. Ackerly. I wanted you to know that your employee [relief-driver’s name] tested positive for marijuana…”

What do you do?

The New Cycle

The New Cycle

Problem:

-Your random selection lists are testing well above your requested rate

The New Cycle

Solution:

-Contact the vendor immediately and demand correction

Regulations & Audits

Regulations and Audits

Problem:

-During an audit/inspection/consultation, you are told that whatever you are (and

have been) doing is incorrect

Regulations and Audits

Solution:

-Ask that the regulation be shown

-Ask if it is required or a best-practice

-Ask if it the personal preference of the individual (with no regulatory basis)

Regulations and Audits

Additional Solution:

-Contact FTA

-Contact an Audit Team Leader

-Contact the Volpe Hotline: Phone: 617-494-6336Email: FTA.DAMIS@dot.gov