The DOT-Qualified Substance Abuse Professional (SAP) William “Reggie” Smith, MPA, CEAP, SAP

Objectives Learn the role and responsibilities of the SAP (49 CFR Part 40 Subpart O). Learn how to evaluate an SAP. Learn the importance of the Return-to-Duty process. Learn the value in a comprehensive monitoring program.

The Substance Abuse Professional Qualifications Licensed physician (Doctor of Medicine or Osteopathy); licensed of certified Social Worker; licensed or certified Psychologist; licensed or certified Employee Assistance Professional; a state-licensed or certified Marriage and Family counselor; or a Drug Abuse Counselor certified by the National Alcoholism and Drug Abuse Counselor Certification Commission (NAADAC), or by the International Certification Reciprocity Consortium/Alcohol and Other Drugs Abuse (ICRC), or by the National Board of Certified Counselors, Inc. and Affiliates/Master Addictions Counselor (NBCC).

The Substance Abuse Professional Must complete qualifying SAP training. Must satisfy a SAP examination provided by a nationally recognized professional or training organization. Must have knowledge and experience in diagnosis & treatment of substance use disorders. Must have an understanding of 49 CFR Part 40, pertinent DOT agency regulations, SAP guidelines and any significant changes. During each three-year period following satisfactory completion of your training and examination, must complete at least 12 hours of professional development hours relevant to performing SAP duties.

The Substance Abuse Professional Role “Gate keeper” “Protect the public safety ”

SAP Assessment Initial Evaluation Must be face to face (40.291a) Must be clinical in nature Psycho-social history Drug and Alcohol history Work, family, personal, interpersonal, mental status, health Must include an assessment tool Michigan Alcohol Assessment Test (MAST) Drug Abuse Screening Test (DAST) Alcohol Abuse and Disorder Identification Test (AUDIT); Substance Abuse Subtle Screening Inventory (SASSI)

SAP Recommendation Recommendation of Assistance ( b1 and c/d) Education Sobriety support meeting attendance Intensive Outpatient Day Treatment Residential Treatment (short term or long term) Medically supervised inpatient includes detoxification Urinary surveillance

SAP Letter Initial Letter to DER (40.311a) Must be on SAP’s letterhead Must be written Must have signature, phone # and date Also must include (40.311c) Employee’s name and SSN Employer’s name and address Specific violation and date Date of assessment Recommendation of education and/or treatment

SAP Letter Must be sent directly to the Designated Employer Representative (40.311a). Copy MAY be sent to 3 rd party. Does NOT require a release. May not be changed or amended (40.311b). Can be modified or changed by the original SAP.

SAP Monitoring in Treatment Must monitor treatment progress Contact with providers Did he/she get there? Is the treatment program adhering to the initial recommendation? Is the employee compliant with the treatment process? Appropriate documentation Insure disability forms completed. Weekly progress reports. Need to revise recommendations Non-compliance may mean higher level of treatment Follow up recommendations Should be included in the completion letter.

Satisfactory Completion of Initial Recommendation Complete follow-up evaluation Face to face Assessment tool Recovery Attitude and Treatment Evaluator (RAATE) Job and Vocational Attitude Assessment Questionnaire and Interview (JAVAA) Determination of employee compliance Treatment discharge summary, completion certificates, Sobriety support meeting attendance forms Prepare for Return-to-Duty Test (observed collection) (90 day pre-employment test not needed)

SAP Letter Of Compliance Letter of Compliance Employee name and SSN Employer name and address Specific violation and date Dates of evaluations and summary of plan Dates of program participation Clinical characterization of compliance Follow up testing plan OPTION of continuing care SAP signature, phone # and date

Follow Up Testing SAP designates the frequency and the length of follow-up testing. Employer is responsible to complete follow-up testing as prescribed by the SAP. Follow-up testing is in addition to random, post accident or reasonable suspicion testing. Not just “more randoms” but a TOOL for employers SAP must prescribe a minimum 6 in first 12 months Can last up to 5 years Designed to be individual in nature Can include alcohol and/or drugs The follow-up testing plan is NOT to be given to employee Goal: Monitor employee to ensure no drug use Follow-up testing must be unannounced and unpredictable

Non Compliance Letter Employer may NOT return employee to duty Inability to maintain abstinence; non compliant with the treatment process; AWOL; SAP to provide a chronological narration of the events and progress of the employee 1/15/ 2035-Admitted to XYZ Day Treatment Program. 1/27/2035-Tested positive for cocaine. SAP re-evaluated level of care with primary counselor. 1/30/2035-Tested positive for cocaine. Met with primary counselor and client. Discussed that the next positive will result in a recommendation of non-compliance and be reported to employer. 2/4/2035-Employee refused to submit to treatment testing. Discharged by treatment program this date. DER notified. Letter contains same basic info as when compliant

Monitoring Responsibility of the employer Review SAP compliance letter Follow up testing plan Sobriety support meetings Continuing care at the treatment facility Personal or relationship counseling Do you have a “Return to Work” agreement? Who is going monitor the employee’s compliance?

Substance Abuse Issues Family Friends Social Legal Financial Occupational Spiritual Health

Evaluate the SAP Credentials/Training Substance abuse experience Problems in assessment and treatment –“Iountkno” –Shy bladder –What you think about marijuana? –Non-compliance with initial recommendations

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