• Reviewing your carrier's lab summaries can help identify errors or areas to address.

Motor carriers that are subject to DOT drug and alcohol testing must manage the records associated with the administration of their programs. One such document is the semi-annual statistical summary. Rather than simply “file away” these reports that are received from your contracted laboratories, they might offer an opportunity to perform a self-audit.

Recordkeeping

The semi-annual reports are sent to you or your consortium/third-party administrator (C/TPA) twice a year. If you have performed fewer than five tests in the six months, you will not receive a report.

If your C/TPA receives them first, you need to ensure they are forwarded to your company. Note that the laboratory should not send the C/TPA a large report that combines tests for everyone who they serve. The reports need to be employer-based.

Invaluable data

This six-month window of information offers the motor carrier an opportunity to reconcile its report against internal tracking.

For instance, how do the number of completed tests compare against:

• Your statistical reporting,
• Billing records from collection sites and Medical Review Officers (MROs), and
• Actual chains of custody and MRO results you have received?

Let’s take a few examples:

Audit issue: The lab summary shows fewer drug tests performed than the number of drivers selected.

Possible action: Find the reason for the discrepancy and correct any problems to keep on track to reach your random test rate.

Audit issue: The lab report shows fewer tests performed than what your collection site billed you.

Possible action: Contact your collection site for clarification to ensure you were not charged for additional tests in error.

Audit issue: The lab shows one test positive for PCP, but the MRO did not report a verified positive test for PCP to you.

Possible action: Dialog with your MRO on the issue. Possible reasons may include a test downgraded to a negative, or the test was canceled by the MRO due to a fatal flaw or a correctable flaw that was not fixed.

Audit issue: The report shows 25 canceled tests due to fatal flaws. Your records do not show any cancellations because they were not communicated to your company.

Possible action: Verify the reasons for the cancellations with your MRO. If you discover it was due to collection site errors, contact your collection site about “error correction training” for the collector(s) in question. Remember, you are responsible for the actions of your service providers, and if it remains a problem or you are not confident in their services, you may need to consider finding another collection site.

Audit issue: The six-month report shows a number of negative dilute specimens. The DOT requires recollections under direct observation for low-level negative based on the MRO’s direction. Your carrier also has a policy of retesting all other negative dilutes (not under direct observation). You see no record of the recollections in the reports.

Possible action: Make sure your designated employer representative (DER) and MRO understand and apply your retest policy. Ask your MRO which tests fall within the scope of DOT-required mandatory retest under direct observation. Any employees who tested within the range and were not retested should be sent immediately, even though it is after the fact.